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["Source","Company","Type of responder","Country","Question No","Question Text","Selected answer","Comment/Suggestion","Standard","Related Chapter/DR","Paragraphs"]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","Further simplification (and in many cases: elimination) of non-adding-value reporting is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","Further simplification is needed. It should not be required for SMEs (who deliver data to the big corporations, even though we are below all \"official\" thresholds) to hire expensive \"ESG\"-consultants\" to be in compliance."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I disagree","No. Many of the remaining points are still not adding any value to companies and shareholders (and the environment), only to \"ESG consultants\"."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I disagree","No. Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I disagree","No. Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","No. Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","No. Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","For both options, further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I disagree","I disagree. Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I disagree"]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.E1.","Comments on deleted datapoints in ESRS E1","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.E2.","Comments on deleted datapoints in ESRS E2","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.E3.","Comments on deleted datapoints in ESRS E3","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.E4.","Comments on deleted datapoints in ESRS E4","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.E5.","Comments on deleted datapoints in ESRS E5","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.S1","Comments on deleted datapoints in ESRS S1","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.S2","Comments on deleted datapoints in ESRS S2","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.S3","Comments on deleted datapoints in ESRS S3","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.S4","Comments on deleted datapoints in ESRS S4","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","22.G1","Comments on deleted datapoints in ESRS G1","I disagree","Further simplification and elimination is needed."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","Keep \"may\". In general, non-mandatory recommendations should be removed - including these."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","Keep \"may\". In general, non-mandatory recommendations should be removed - including these."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","The word \"fair\" is undefined makes no sense at all. Remove everything and all references related to a \"fair representation\"."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Most investors don't care. The benefits have to be larger than the cost."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","Does not make sense. There is only one planet."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The area is way to complex for anyone to create anything. Eliminate it."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","Simply eliminate Appendix B."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","The phrase \"ecological integrity\" makes no sense. Eliminate everything related to that."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","It's unclear how many genders there are. Just remove this."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","In the practical world, this has no effect. Simply remove it."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Simplify or eliminate."]
["Survey","Net Zero Game ApS","Preparer (non-financial preparing a sustainability report)","Denmark","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"It's worrying how the Green Transition was hurried through the European Parliament just before the election. We blame the European Commission, the Eurocrats and the Members of the European Parliament."]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","S4"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","I believe that the mandatory data point need to stay for all of the ESRS. Companies need to take actions."]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Again companies need to take action. The transition plan is important."]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Lisam Systems SA","Consultant (including software vendor)","Belgium","35.E1-1."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-1 - Transition plan for climate change mitigation",""]
["Survey","Independent","Other - please specify (required)","Netherlands","35.S1-15."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Gender Pay | To create actual insight in the glass ceiling/ sticky floor concept; use a split + a count as per DR S1-9 definition \"Top management\" and \"Other staff\". E.g. - 82% ( 6F, 123M) and +2% (253F, 286M) - state that undefined (X) is added to the smallest group (as per EBA guidelines).","S1","Disclosure Requirement S1-15 - Remuneration metrics",""]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We still see a high amount of effort when it comes to tagging the report."]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Option 2 is more feasable for companies"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I agree","I hope the description of the remaining data points is getting more detailled and easier to calculate for companies (f.ex. gender pay gap)"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","The amout of cases would increase for us"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","The gender pay gap is really hard to measure for many companies"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","35.E5-5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","information on the expected durability is for machines really hard to measure","E5","Disclosure Requirement E5-5 - Resource outflows",""]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","35.S1-8."," Do you agree with the amendments of this chapter? ","I agree",null,"S1","Disclosure Requirement S1-8 - Diversity metrics",""]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","35.S1-11."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","In small companies the metrics  about people with disabilities could disclose who of the employees has a disability - data security","S1","Disclosure Requirement S1-11 - Persons with disabilities",""]
["Survey","Max Automation","Preparer (non-financial preparing a sustainability report)","Germany","35.S1-14."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The familiy-related leave is a right for every employee in germany.","S1","Disclosure Requirement S1-14 - Work-life balance metrics",""]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","It has been clarified and shortened (good). However, value-chain consideration is still too strong (e.g., small-med-sized companies w/ complex supply chains, or with very large suppliers (\"Broadcom\") will still have problems. Also, it should be further simplified such that the required AUDIT (validation) becomes simpler and CHEAPER."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","Still too complex and time-consuming. Also, adds unnecessarily to AUDIT cost! (These exploded in the last 2 years, meaning that less money may be spent on \"real\" ESG actions.) Also, mitigation and any forward-looking plan or assessment always bears the risk of being partially wrong. This leads to an endless debate of why things went the way they did though assessed / planned differently. Waste of time and money."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","Readability got somewhat better (which was drastically necessary). In total, the requirements on the statement are still too many / too complex. From that perspective, the use of appendices does not help much. A full ESRS report is not \"elegantly\" to read."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","ESRS 2 indeed seems to having been revised massively. It got much shorter and more readable. However, its accumulated requirements are still too complex, given stakeholder and value-chain consideration and IRO-SBM interaction."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Readability improved. However, complexity is still too high IN PARTICULAR since reporting-obligation threshold, BIGGER companies are not discriminated from VERY BIG companies. For the former, the accumulated necessary effort is still too high, too time-consuming and too costly."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS2; E5","This refers to ESRS 2 GDR-A and ESRS E5, inflow / outflow. Together, they are completely unpractical for manufacturers of complex (B2) electronic products, specially very complex products sold in small numbers. Such products can easily contain 10,000s of complex electronic components that in turn can easily contain 1,000s of substances. And detailed analysis for the report is either close to impossibly or meaningless. The letter results from aggregation w/w. Then, risk is that total weight, e.g., of secondary material is vastly dominated by metal shelves, and not of more prcious components, HOWEVER, according to LCA, the latter components have a FOR HIGHER environmental impact (and often are not allowed to contain secondary material). That is, the answer can be misleading since it does not reflect any important components details. Suggest a massive revision here for complex electronic goods."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","The simplifications make sense."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","The simplification makes sense."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Option 2! That is very clear. Quantitative (financial) risk is ALWAYS an estimate, and in many cases a guesstimate. The value of option 1 is very doubtful. It can also be doubted that this leads to a \"loss of information important to investors\" at all."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","It may have to be further simplified since for relevant industries, sector-specific requirements are not available, hence whatever expectations may never be fully met (or the expectations are wrong).",null,null,""]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","It seems appropriate. So far, we did not report on IFRS S1/2, hence this answer may be weighted less."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Deletions are ok - do not reverse (4th option above)! However, very high number and associated effort of datapoints. Effort still too high, with the associated risk that smaller companies cannot report w/o consulting firms (\"if you need consulting, it is WRONG\").  GDR-T IMO is still too complex."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","About ok given that climate change is (still) the most relevant topic."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","Seems feasible. However, this has never been material for us."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","Seems ok-ish. Never been material for us, and I doubt that companies where this is material will have all the required data."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","Same as above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.E5.","Comments on deleted datapoints in ESRS E5","I partially agree and partially disagree","See my earlier comment on inflow/outflow. This needs revision!"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","About ok. We have all this data..."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","Seems good!"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","Seems ok."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","Seems ok."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","22.G1","Comments on deleted datapoints in ESRS G1","I partially agree and partially disagree","Seems ok as well."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Water - ok Biodiversity - I strongly doubt Business conduct - ok (good)"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","Only ESRS 2 makes sense. I doubt tat E2-4 makes sense since many companies will not have this information. Same E5-4 (see my earlier comments). E5-5 is ok (good)."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","I agree with the \"increased audit cost\" argument stated above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","I agree w/ the opposers. Intensity targets always have the risk of shielding zero improvements. Also, I don't agree with the financing argument of the promoters. I also agree that ALL OTHERS also have to use/make complex assumptions/estimates, etc."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","Makes sense, and reliefs companies with small \"sales\" offices in many countries."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","It makes sense. More relevant, even stricter reporting requirements will NEVER completely avoid that (too) low salaries are paid..."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","It seems duplications and other less-relevant / irrelevant DRs have been removed which is good. IMO, the stongest area for SFDR-ESRS alignment is S1/S2, and a reasonable level of alignment seems to be achieved. No further comments here."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Where this topic may become more relevant (material) in the future, this shall be kept as simple as possible. IMO, most companies would not survive the same required effort for E2-E4 (E5), plus S2-S4, that they have to spend for E5."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","This wil lbe problematic for several companies, and will not make the world a better place."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","Deletion is ok, no severe risks re. SMEs seen"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","For us, E1 has outstanding relevance. As such, it is ok."]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","given relevance, this seems ok"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","see above"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ok, and should not be too problematic for companies"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ok"]
["Survey","Adtran Networks SE","Preparer (non-financial preparing a sustainability report)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Maintain keeping it simple. The challenge is to give complex topics a seemingly simple framework. Reporting shall not necessitate consulting!"]
["Survey","Reclaim Finance","NGO","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The proposed amendments significantly simplify the DMA process, providing further flexibility to companies on their double materiality assessment while clarifying certain dimensions (including regarding the interactions between impacts, risk and opportunities and the integration of remediation measures).   However, uncertainty remains on how materiality will be assessed, notably in the case of potential impact. Indeed, in the draft, the materiality of potential impacts would be considered depending on the scale and likelihood of this impact. In the case of negative impact, this means that highly negative consequences could be ignored if they are deemed unlikely. The Efrag somewhat acknowledges the risks this situation creates by stating that for potential human rights impact their scale take precedent over their likelihood. Yet, such a precautionary approach is also needed for other potential negative impacts, including when it comes to climate mitigation, pollution prevention and biodiversity preservation. We therefore call on the Efrag to extend the approach proposed for human rights to other impacts and adjust the draft to ensure all potential negative impacts are immediately considered material if they reach a certain scale."]
["Survey","Reclaim Finance","NGO","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","The new guidance could contribute to more relevant and comparable reporting. We also believe it could contribute to simplify implementation, as it settles some important question practitioners face while assessing materiality.   We agree with the SRB members that supported the inclusion of this provision. We stress prevention and mitigation actions are taken into account in the proposed guidance, resulting in various disclosure requirements levels. On the contrary, we stress that enabling companies to consider topics as non-material as soon as they deploy significant mitigation or prevention actions simply hides risks and increase the chances of unaccounted negative impacts that would emerge due to mitigation failures."]
["Survey","Reclaim Finance","NGO","France","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","Overall, these changes improved the readability of the ESRS and made them more user-friendly. They do not have significant consequences for the content and relevance of the ESRS."]
["Survey","Reclaim Finance","NGO","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","If the proposed changes contributed to simplify the standard and make it more user-friendly, we note the removal details from topical standards give less visibility to these elements and therefore could result in lower quality reporting."]
["Survey","Reclaim Finance","NGO","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","If the changes somewhat contribute to clarity - notably through relocating \"shall\" datapoints in the main body and adjusting application requirements - we stress that the complete removal of voluntary (\"may\") datapoints could on the contrary bring confusion, desincentivize ambitious reporting and reduce disclosure usefulness.   Indeed, while the NIMG picks up some of the removed voluntary disclosure elements, its role is not the same as the voluntary data points and it does not seem to include all of these elements. We therefore suggest that the Efrag at least (i) fully reflects the former voluntary disclosures in the NIMG or an additional documents and (ii) makes clear that companies can go beyond the mandatory standard and build on these elements."]
["Survey","Reclaim Finance","NGO","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Providing the changes made, NIMG are highly relevant to ESRS usability. NIMG should also play a role in fostering best practices, giving companies more information on how best to report on key datapoints. Yet, so far, NIMG are not sufficient to do so and largely serve as additional non-binding supplement to ARs. If time constraints may not enable to do this in the first version, updates could be planned to integrate best practices and guide companies further in applying the ESRS. Furthermore, NIMG could feature more prominently former voluntary datapoints."]
["Survey","Reclaim Finance","NGO","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","We warn about the cumulative impact of the many proposed reliefs that will increase the differences between disclosures and reduce overall quality. They add new filters in the reporting process that are largely incoherent with the goal of the ESRS and could even add to complexity.  We especially note that: - The relief \"undue cost or effort\" is an important change that implicitly adds a new layer to how companies determine which information to report. While materiality is tied to impact/risk, this new filter is solely tied to the burden of reporting for the company. Therefore, this is clearly incoherent with the spirit of the ESRS and a potential source of misreporting. We also stress it does not simply the process, but rather adds some complexity.  - The relief that enables indefinite and unconditional exclusion of data from joint operations where the entity lacks \"operational control\" is not relevant and could significantly impact the quality and extent of reporting. Indeed, companies can most often obtain data through financial control or influence over the operator, even when they do not have operational control. Additionally, this could breach the \"risk-based\" approach integrated to the ESRS, whereby companies are to identify potential negative sources of impact/risk along their activities. Here again, the change could add to complexity. - The possibility to increasingly rely on estimates instead of direct data should be assessed carefully. This is likely to contribute to reduce data gathering by companies and related demands along their supply chains. If this could reduce the work necessary to carry out ESRS compliant reporting, it therefore also reduce its potential positive impact and the accuracy of reported data. The gathering of direct data should remain the preferred option, even when the use of proxies is authorized."]
["Survey","Reclaim Finance","NGO","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","Providing the potential significant impact of this relief, we support the use of a time limit as proposed by Efrag SRB. Furthermore, we warn about the cumulative effect of other relief as highlighted in our response to question 17."]
["Survey","Reclaim Finance","NGO","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","The anticipated financial effects are essential to understand how/if a company is prepared. Sustainability risks are not considered in traditional risk management, and the proposed relief would contribute to maintain this situation and therefore to increase systemic risks. It will always be challenging to quantify the financial effects and many uncertainties will always remain, but this does mean that this data is not useful or relevant. If the Efrag can clarify that quantification enable for some degree of inaccuracy, companies should not be granted a full relief."]
["Survey","Reclaim Finance","NGO","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","Paragraph 40-42 establish require disclosure of the minimum elements needed to understand potential financial effects of physical and transition risks. Further reductions would significantly impair the relevance of this information, especially for financial institutions. In fact, additional elements - for example, when relevant, the value of the infrastructure at risk - would be relevant and help financial institutions fulfill to their own prudential requirements.",null,null,""]
["Survey","Reclaim Finance","NGO","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Interoperability should not come at the expense of the relevance and usefulness of the standard. Yet, several of the reliefs introduced to align with the IFRS on undue cost or effort and quantitative financial effects could have this effect.   We especially note that the relief \"undue cost or effort\" is an important change that implicitly adds a new layer to how companies determine which information to report. While materiality is tied to impact/risk, this new filter is solely tied to the burden of reporting for the company. Therefore, this is clearly incoherent with the spirit of the ESRS and a potential source of misreporting. We also stress it does not simply the process, but rather adds some complexity."]
["Survey","Reclaim Finance","NGO","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Reclaim Finance","NGO","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Overall, we stress the Efrag proposal represents the maximum reduction in data point possible without abandoning the EU Green Deal objectives.   The proposed reduction will significantly limit comparability between disclosures, through much lower granularity and less comparable reporting practices. It will also likely reduce data quality, as companies have much less guidance on what exactly to report and how. Yet, we acknowledge that it largely preserves the key datapoints related to EU objectives and necessary to understand impact and risk at company level. Any further reduction would no longer solely affect the granularity and quality of reporting, but would instead directly affect the scope of the ESRS and the information essential for EU objectives."]
["Survey","Reclaim Finance","NGO","France","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","We stress the Efrag proposal represents the maximum reduction in data point possible without abandoning the EU Green Deal objectives.   For E1, much like for the other topical ESRS, the proposed reduction will significantly limit comparability between disclosures, through much lower granularity and less comparable reporting practices. It will likely reduce data quality, as companies have much less guidance on what exactly to report and how.   For example, there are much less data points detailing the design of decarbonization targets. Yet, many factors are crucial to understand their potential impact. In this situation, some companies will provide sufficient data but others simply won't.   Similarly, datapoints on transition plans are critically insufficient to cover all of the needed aspects of transition planning and to enable a robust assessment of published plans.   In this context, we stress that any further reduction would be detrimental to EU climate goals. We also note Efrag could provide additional guidance on specific points, notably decarbonization targets and transition plans, through NIMG and/or specific documents."]
["Survey","Reclaim Finance","NGO","France","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We strongly agree with these exceptions. In the context of the removal of voluntary datapoints, the identified datapoints that are highly relevant to their respective topical standards should be preserved and become mandatory."]
["Survey","Reclaim Finance","NGO","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","Added mandatory datapoints usefully supplement preexisting ones and either contribute to consistency or are related to EU policy priorities."]
["Survey","Reclaim Finance","NGO","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","I  interpret the CSRD as requiring fair presentation and see this change as a clarification rather than anything else. I believe it supports the various goals of the review."]
["Survey","Reclaim Finance","NGO","France","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Reclaim Finance has conducted a detailed study of the decarbonisation targets of banks (see: https://reclaimfinance.org/site/en/the-need-to-redesign-bank-decarbonization-targets/) and is now studying investor targets. The NGO also contributed to work around target setting on insurers. This work notably showed that current methodologies - mostly based on PCAF - for financed emissions are largely inadequate, insofar as they are not related to real emission and not likely to induce change in the real economy.   One of the key problem with the PCAF methodology for financed emissions is the use of an attribution factor that leads to change in financed emissions due to changes in the value of companies and not of their emissions. This problem is somewhat acknowledged by PCAF itself and by its users.   Yet, solutions exist and other metrics used do not reproduce this mistake and are more directly linked to real-economy practices and emissions: 1) For all sectors except the fossil fuel sector, financial institutions can notably rely on physical intensity targets (or so-called \"weighted average physical intensity\" WAPI). This metric type is already used by many financial institutions.  2) For the fossil fuel sector, that must in time be phased-out, financial institutions can rely on targets to reduce the volume of financing. If emission targets are to be used, absolute targets should be used but they should not rely on attribution factors, and thus simply reflect the absolute emission of all companies financed in the sector.   We therefore highlight that the question does not tackle the most pressing issue with financial institution target setting and emission reporting. We urge the Efrag to integrate in the ESRS requirement to: - Report on WAPI sectoral targets for all sector except fossil fuels; - Report on absolute emissions without attribution for fossil fuels."]
["Survey","Reclaim Finance","NGO","France","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","Reductions are mainly made on data that can be relatively easily derived, and therefore disclosures still cover PAIs. The Efrag should abstain from further changes, notably considering the upcoming SFDR review."]
["Survey","Reclaim Finance","NGO","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","The review creates a gap in term of metrics. The new AR should at least include references to key sources including the Science-Based Target Network (SBTN), Nature Positive initiative and the Taskforce on Nature-related Financial Disclosures (TNFD). Additional references could be made to initiatives and methodologies that can help fulfill The Kunming-Montreal Global Biodiversity Framework, for example the Forest500."]
["Survey","Reclaim Finance","NGO","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We stress the Efrag proposal represents the maximum reduction in data point possible without abandoning the EU Green Deal objectives."]
["Survey","Reclaim Finance","NGO","France","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We stress the Efrag proposal represents the maximum reduction in data point possible without abandoning the EU Green Deal objectives."]
["Survey","Reclaim Finance","NGO","France","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We stress the Efrag proposal represents the maximum reduction in data point possible without abandoning the EU Green Deal objectives.   Specific comments on E1 will be provided in section 3 of the consultation."]
["Survey","Reclaim Finance","NGO","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"1) The proposal represent the maximum reduction in data points  Overall, we stress the Efrag proposal represents the maximum reduction in data point possible without abandoning the EU Green Deal objectives.   The proposed reduction will significantly limit comparability between disclosures, through much lower granularity and less comparable reporting practices. It will also likely reduce data quality, as companies have much less guidance on what exactly to report and how. Yet, we acknowledge that it largely preserves the key datapoints related to EU objectives and necessary to understand impact and risk at company level. Any further reduction would no longer solely affect the granularity and quality of reporting, but would instead directly affect the scope of the ESRS and the information essential for EU objectives.  2) Several of the reliefs introduced are concerning and could significantly reduce the usefulness of the standard  If the overall proposal strikes a balance between simplification and data needs, the proposed reliefs introduce additional stages and filters that are likely to significantly reduce its usefulness. This is especially the case of the reliefs on \"undue cost or effort\" and operational control.   3) The standard remains inadequate for financial institutions and proposed specific references are not relevant  The standard should be significantly adapted to be easily implementable by financial institutions and reflect the specificities of their activities.   Yet, in the current standard the only adjustment proposed are: 1) Potential difference in requirements on target disclosures; 2) Reference to PCAF methodology on financed emissions. As explained in our response to question 26, this is largely inadequate."]
["Survey","Reclaim Finance","NGO","France","35.E1-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree",null,"E1","Disclosure Requirement E1-1 - Transition plan for climate change mitigation",""]
["Survey","Quantis","Consultant (including software vendor)","Switzerland","35.S4-3."," Do you agree with the amendments of this chapter? ","I disagree","In the version downloaded through the EFRAG's website, there is an error as §15 is noted as §14 (so §14 is present twice).","S4","Disclosure Requirement S4-3 - Actions and resources related to consumers and end-users",""]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree",null,null,null,""]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","More simplification would have been more appropriate, esp. in the S standards and G1"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Infraserv GmbH und Co. Höchst KG","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E1","The exposure draft of ESRS E1 proposed removals of one or two illustrative table formats (eg in AR 60 and AR 64). We think these can usefully be retained in the NMIG. Such tables can be helpful for companies unsure about how to report information publicly, and promotion of these tables will support standardisation of reporting, which is helpful for stakeholders."]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See comments in third section of this survey, on specific paragraphs.  Specifically we advocate for retaining parts of  E1-4 para 34. (c) and (d),  E1-6 AR 46. (i),  E1-7 AR 62 (d) and (e) and  E1-7 AR 63 (e) and (f)  (all references to the current version of ESRS E1 (rather than to the Exposure Draft)."]
["Survey","Exponential Roadmap Initiative","Other - please specify (required)","Sweden","35.E1-8."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","See comments in Excel template.","E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Diskussion with auditors suspected"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E1; E2; E5"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","pretty good, but still too much datapoints included",null,null,""]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","absolutely !"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","Personally no experiences in such calcultion"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","More info than 'unadjusted ratio' would be appreciated"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Freudenberg FST GmbH","Preparer (non-financial preparing a sustainability report)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"My biggest concern is still, that auditors (even at limited assurance) will come up with insignificant issues. Very little on experiences but a high interest on being received as important,  becomes rapidly a dangerous mixture. Auditing should be opened for technicaly oriented service providers. (like ISO-certifiers)."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Positive: Elimination of most detailed topics, merged topics are easier to report on, non-mandatory status leaves a certain amount of freedom"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Not sure which effect it will has, maybe excessive reporting on potential impacts."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","Approaches seem to support the avoidance of repetition across sections (we   noticed) and a focus on the most relevant information within the sustainability statement. It makes it possible to incorporate additional information we classify as useful for our expected readers (e. g. topics from older reports) and to make use of a readerfriendly structure."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Elimination of topical specifications to GOV, SBM and IRO seems to make sense in order to avoid double reporting within the statement and fragmentation of topics in the report."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Mandatory application requirements below the respective Disclosure Requirement makes it more understandable and the information within the ESRS less fragmented."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The relief regarding the reporting of partial scopes and the possibility to use estimates is very helpful. It should be mentioned that companies shall disclosure where these estimates come from/how they are calculated, for example in the statements appendix."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","It makes it possible to disclosure the data we have at the moment and to show how we improve data quality step by step."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","The current quality of data could be a bottleneck to measure financial effects. Too much uncertainties could result in useless information and burning of capacities. If improvements are made to address these problems companies might start reporting on a voluntary basis to stand out from the crowd."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","It seems meaningful to provide the data that is still required in ESRS E1 but it might be difficult to provide meaningful data for all sites of a Group. Data on these data points might not be available at the moment and the calculation might take time.",null,null,""]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I disagree","Not assessment possible"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","No additional burden"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","At the moment the risk to report excessive information seems to be very high. And Stakeholders have limited time to filter for relevant information."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Not assessment possible"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","No assessment possible, outcome/improvement unclear"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","No assessment possible"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","No assessment possible"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Not sure but an alignment with SBTN and latest trends might help. Furthermore guidance for biodiversity and ecosystems-related targets would be welcomed."]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","No assessment possible"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","No assessment possible"]
["Survey","Kurtz Ersa","Preparer (non-financial preparing a sustainability report)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Very long survey, hard to check and assess everything in detail."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","This year, although non mandatory, we found that some of the points, repeated them selves. We thought that during our filling in of the points, there were repeated answers and they were a bit confusing, rendering the report a bit boring."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","I agree with the comments from other members. Some of the point description was a bit confusing and for some smaller companies not easy to assess and see exactly what was required to be transcribed. It needs to be simplified and adequate for smaller companies to be motivated to fill in, even if non mandatory"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","I think it is quite important to simplify the requisites, mainly the way the reporting should be done. If it gets simpler, more people will be willing to present sustainability reports"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Its very important to be able top link certain disclosures with requirements. In the begining the ESRS E1 could be confused when we read the other topical requirements and we would have repeated information"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","When eliminating the may disclose requirements, it simplifies the requirements that are mandatory and the simplifies the reading of the stantard. The previous document had a mixture of may and shall and sometimes that would be more confusing."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E1","Regarding this quite big requirement, i think it seems more clarified and simpler to read. Must still read it more attentively, but seems easier to comprehend."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","It is quite important to simplify metrics for the investments, etc. Sometimes it is difficult for a company like our (pastrey and bakery) to relate to some info mixing sustainable investments and all that data. Sometimes it is also difficult to be able to include some equipments that improve energy production, but cannont be included when relating to finantial investments, because there is no relation to NACE in some industries."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","I think it is quite important to permit the exporsure of information if the company only considers certain scopes. When a company is begining to report its progress, most data is not available and when available, it is still being adapted to the more adequate assumptions. It is always a work in progress and sometimes the feedback it gets from its upstream chain is not always complete. Mainly when working with smaller companies and suppliers."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Like i refered to before. Sometimes the information regarding sustainable improvements is not imediately and directly relatable to finances. Sometimes they are \"only\" improvements like adapting taps to reduce water usage etc and the real results are not immediately measurable. Does not mean that the company is not making a big effort to improve. Sometimes ii is also important to include some improvements that are not possible to be done, because they will interfere to a certain quality standard of a product, which would make the customer reject it."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","One issue that sometimes makes it hard to disclose is certain aspects of business secrecy. Dependening on the markets, it the company reveals lots of information, when it is compared with other companies that do not need to disclose, that can be used for non correct business activities. Its important to consider that the info shall be disclosed, but with more care",null,null,""]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","There are businesses that do not have sectorial standards adapted to them. Frozen bakery and pastry. Its quite hard to relate to them when speaking of ESRS standards."]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.E1.","Comments on deleted datapoints in ESRS E1","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.E4.","Comments on deleted datapoints in ESRS E4","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.S1","Comments on deleted datapoints in ESRS S1","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.S2","Comments on deleted datapoints in ESRS S2","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.S3","Comments on deleted datapoints in ESRS S3","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.S4","Comments on deleted datapoints in ESRS S4","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","22.G1","Comments on deleted datapoints in ESRS G1","I agree","Very important to focus on important points and sometimes join very similar points into one point"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Although all the topics are very important, the main issue sometimes, when speaking of the protection of biodiversity, is the importance that the customer gives to certain issues. When using suistainable raw materials, like cocoa, palm, etc, there is a natural increase in the price of the material and most customers want to use sustainable raw materials, but not pay the price. And a company must have some profits to be able to thrive and improve"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","good change"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","I think with these changes and with the companies that are pbligated to report this year, we will have more feedback on the difficulties and improvements necessary"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","It is still a very new subject and probably there are certaisn aspects that have not been correctly considered and evaluated. Only with some time we will be able to have a correct judgement"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","I agree as disclosure per country could give a more detailed idea of issues that are more or less relevant"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","yes, because sometimes there is a very big difference in wages and the is not considered an honest comparing between companies"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","na"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","Its not an easy topic to discuss"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","its still a work in progress"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","PANIKE SA","Preparer (non-financial preparing a sustainability report)","Portugal","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"I agree that it is a start, but like with most standards, there will be more amendements as people start working with them"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","While the proposed amendments to ESRS 1 aim to simplify the Double Materiality Assessment, I do not consider this objective sufficiently achieved. In my view, the intended balance between simplification and robustness has not been met.  The explicit allowance for both bottom-up and top-down approaches is positive in principle, yet the absence of clearer methodological guidance leaves too much room for divergent interpretations and inconsistent practices.  Key uncertainties are not resolved structurally but shifted to preparers under the new principle-based approach. This places even greater weight on ESRS 2, which I believe is likely to harm, rather than improve, auditability and comparability. Instead of clarifying the missing logical links between impacts, risks and opportunities (IROs), topics, and Minimum Disclosure Requirements (MDRs), the amendments merely rename \"matters\" as \"topics\" and allow reporting at either topic or subtopic level. This \"do-it-yourself\" logic may increase flexibility, but it reduces comparability and makes auditability more difficult. From my perspective, the better path would have been to strengthen the topical standards. That would have created greater precision and thereby improved auditability and comparability across undertakings.  I welcome the stronger role of materiality as a general filter and the emphasis on fair presentation. However, these changes alone do not sufficiently reduce the documentation burden. The streamlining of the topic list is helpful, but aggregation and disaggregation rules remain unclear and risk leading to either overly abstract or excessively detailed disclosures.  In conclusion, I do not believe that the amendments adequately simplify the DMA process. From my perspective, the ESRS remain deeply flawed at their foundation, and the current amendments represent little more than cosmetic adjustments rather than the structural improvements that would be required."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","I appreciate the intention behind the new guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in the assessment of materiality of negative impacts. However, I do not believe that these provisions actually contribute to simplification, relevance, or comparability. On the contrary, they introduce an additional layer of complexity that runs counter to the stated mandate of simplification. Instead of reducing divergence in practice, the new rules may create more uncertainty for preparers and reviewers. This is because the guidance effectively shifts the burden of interpretation onto companies, who must navigate subtle distinctions between gross and net views over multiple periods. While I recognize the effort to clarify an important implementation question, I do not believe the new guidance fulfils its purpose. It risks making the DMA more complicated rather than simpler, and therefore does not align with the simplification mandate set out for the ESRS revisions."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I disagree","While I acknowledge the intention to simplify the interaction between ESRS 2 and the topical standards, in my view the amendments do not achieve this goal. Instead of reducing complexity, they shift key structural uncertainties onto the preparers through a principles-based \"do-it-yourself logic.\"  By eliminating many topical specifications and relying more heavily on ESRS 2, the architecture places disproportionate weight on the General Disclosure Requirements. This approach increases discretion for preparers, but at the expense of auditability and comparability across undertakings. What was intended as simplification risks creating greater divergence in practice.  In my opinion, a more effective and proportionate path would have been to strengthen the topical standards. This would have introduced greater precision, provided clearer guidance for preparers, and ensured that disclosures remain both consistent and comparable."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","In my view, the disclosure requirements on Anticipated Financial Effects (E1-11, formerly E1-9) should be removed entirely.  First, the datapoints rely on a very high degree of estimation, forward-looking assumptions, and prognostic modelling. This inevitably introduces excessive uncertainty into reporting, and the results are neither robust nor auditable. Instead of improving decision-usefulness, the disclosures risk producing figures that are speculative and potentially misleading for users.  Second, there is currently no widely accepted scientific methodology or internationally recognized standard for calculating such anticipated financial effects in a consistent way. Without a sound and harmonized methodological foundation, comparability across undertakings cannot be ensured. This undermines the objective of creating reliable and decision-useful sustainability reporting.  For these reasons, I do not believe the requirements strike the right balance between reporting effort and users' needs. On the contrary, they add complexity and costs without generating reliable or comparable insights. I therefore recommend that this disclosure requirement be deleted in its entirety until a scientifically recognized and standardized methodology has been established."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","I strongly disagree. In my view, the decision to move six datapoints from \"may disclose\" to \"shall disclose\" is not compatible with the simplification mandate given to EFRAG.  1. Violation of the simplification mandate The political mandate was clear: to simplify and reduce reporting obligations. By upgrading optional datapoints into mandatory ones, this change runs directly counter to that objective and contradicts the political will behind the revision process.  2. Introduction of new obligations Even if EFRAG argues otherwise, these datapoints do create new obligations. Previously, they were not clearly required. By explicitly defining them as mandatory datapoints, they now impose additional reporting burdens that did not exist in practice before.  3. Unsound comparison of datapoints It is methodologically flawed to justify the addition of quantitative datapoints by comparing them to the removal of narrative datapoints. Narrative disclosures often build on existing texts, while quantitative datapoints require extensive manual effort, system changes, and significantly higher costs. The workload is therefore not comparable.  4. Insufficient and unconvincing rationale The reasoning provided is not sufficiently substantiated. In some cases, it is objectively questionable—for instance, the assumption that most companies already have a biodiversity strategy is not supported by evidence.  5. Impact on competitiveness By adding new mandatory datapoints without robust justification, the approach risks weakening the competitiveness of EU companies compared to non-EU peers who do not face equivalent obligations.  For these reasons, I do not consider this approach acceptable. It undermines the simplification mandate, creates new burdens, and is not supported by sufficiently sound reasoning."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","I strongly disagree. In my view, the addition of four new datapoints is not compatible with the simplification mandate that EFRAG has received.  1.\tViolation of the simplification mandate The mandate was clear: not to increase reporting obligations. Adding new mandatory datapoints directly contradicts this objective and the political will for simplification.  2.\tIntroduction of new obligations EFRAG argues that these datapoints do not add new requirements because they relate to existing disclosure objectives. I cannot agree. Datapoints such as percentage of total weight of raw material or microplastics were not previously required in this form. They clearly represent new, specific obligations.  3.\tData availability and reliability The required information, such as the percentage of total weight of raw material, is in most cases simply not available. Companies do not collect data at this level of granularity, nor do recognized methodologies exist. This places undertakings before hurdles that are practically insurmountable. Where companies attempt to fill the gaps with estimates, such estimates cannot be considered reliable or robust due to the lack of underlying data. The resulting figures risk being speculative rather than decision-useful.  4.\tUnsound justification by comparison It is not a sound argument to offset new quantitative datapoints by reducing narrative datapoints. Narrative disclosures often build on existing information, while quantitative datapoints require new processes, significant manual work, and higher costs. The workload is therefore not comparable.  5.\tCompetitiveness concerns Adding new highly demanding datapoints without a sound methodological foundation risks undermining the competitiveness of EU companies compared to peers elsewhere.  For these reasons, I do not believe the inclusion of these datapoints is justified."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","As above"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","As above"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The disclosure requirements on Anticipated Financial Effects (E1-11, formerly E1-9) should be removed entirely (as explained above)."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Adding new mandatory datapoints directly contradicts the simplification mandate and the political will."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Adding new mandatory datapoints directly contradicts the simplification mandate and the political will."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Adding new mandatory datapoints directly contradicts the simplification mandate and the political will."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Adding new mandatory datapoints directly contradicts the simplification mandate and the political will."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","In my view, the disclosure requirements on non-employees should be deleted entirely, as they add disproportionate complexity without providing decision-useful information."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","I believe that value chain reporting should be limited to tier 1 in alignment with the CSDDD, as this ensures consistency while keeping the reporting scope manageable."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The disclosure requirements on payment practices should be deleted entirely, as they create an extremely high administrative burden without a proportionate benefit."]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","NEW AG","Preparer (non-financial preparing a sustainability report)","Germany","35.E5-4."," Do you agree with the amendments of this chapter? ","I disagree","The mandate was clear: not to increase reporting obligations. Adding new mandatory datapoints directly contradicts this objective and the political will for simplification. The required information, such as the percentage of total weight of raw material, is in most cases simply not available. Companies do not collect data at this level of granularity, nor do recognized methodologies exist. This places undertakings before hurdles that are practically insurmountable. Where companies attempt to fill the gaps with estimates, such estimates cannot be considered reliable or robust due to the lack of underlying data. The resulting figures risk being speculative rather than decision-useful.","E5","Disclosure Requirement E5-4 - Resource Inflows",""]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Q-Park BV","Preparer (non-financial preparing a sustainability report)","Netherlands","35.E1-8."," Do you agree with the amendments of this chapter? ","I disagree","We find the Scope 3 a senseless exercise as it is based on estimations, assumptions and other non-sensical data. In addition there is practically no level of influence possible to decrease the number. Second, being a full EU company, everything is regulated and organised, i.e. strengthening the climate impact goals on so many levels already. Third, most of the parties we work with are too small - we cannot ask them for any information et cetera. Why not loos the whole Scope 3 and focus on Scope 1 and Scope 2. Data that makes sense, is not build on assumptions nor benchmarks and actually influences our decision-making processes. When aiming to make things simple - Scope 3 gives me the most headache, the least support and makes no sense on an impact level.","E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Transparentem","NGO","United States","35.S2-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The draft S2-1 addresses forced labor and trafficking in human beings only through generic policy statements (paragraphs 11-12), missing the specific recruitment practices that often create forced labor conditions. This creates a critical policy gap.  Specific addition needed: Add new paragraph to S2-1: \"The undertaking shall state whether its policies explicitly require that workers do not pay recruitment fees or related costs for their employment, in line with ILO guidance, and establish procedures for full and timely reimbursement when such payments are identified.\"  Rationale: 1.\tILO Authority: The International Labour Organization has established clear guidance that workers should not pay recruitment fees, providing authoritative international standards for policy requirements.  2.\tMateriality: Recruitment fee practices create significant business risks. Workers paying for jobs indicates fraudulent recruitment—a primary forced labor pathway generating legal, reputational, and reputational risk, including having companies being impacted by forced labor import bans, having to pay back millions of dollars in recruitment fee reimbursements, and drops in share prices and revenue  3.\tImplementation practicality: This is a policy-level requirement (not metrics), addressing EFRAG's simplification objectives while covering material risk. Companies can reasonably establish and communicate such policies.  4.\tGlobal alignment: GRI is developing labor standards (finalizing 2025-2026) specifically including \"fair recruitment\" requirements. EFRAG's omission creates unnecessary framework divergence.  5.\tInternal consistency: Other severe labor violations receive policy attention in S2-1. Recruitment practices—as a forced labor pathway—warrant equivalent treatment.  This addition maintains the simplified policy approach while ensuring coverage of concrete practices that indicate forced labor risk, supporting both stakeholder information needs and EFRAG's objective of relevant, decision-useful reporting.","S2","Disclosure Requirement S2-1 - Policies related to value chain workers",""]
["Survey","Transparentem","NGO","United States","35.S2-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","S2-3 creates a critical implementation gap by requiring disclosure of actions to \"prevent, mitigate and remediate material negative impacts on value chain workers\" without specifically addressing forced labor, despite forced labor being explicitly mentioned in the policy requirements (S2-1, paragraph 11).  The inconsistency problem: Companies must state whether they have forced labor policies (S2-1) but aren't required to describe concrete actions to address this severe violation (S2-3). This makes the policy requirement meaningless in practice, as companies can claim forced labor policies but do not have to demonstrate implementation.  Internal framework contradiction: S2-3 requires specific action disclosures for other worker rights issues, but one of the most severe labor violations (forced labor) receives only generic treatment. This undermines the standard's logical structure and effectiveness.  Comparison within S2: Other disclosure requirements demonstrate EFRAG expects substantive action reporting: •\tGrievance mechanisms require effectiveness assessments •\tHuman rights incidents must be disclosed •\tWorker engagement processes require detailed description •\tRemediation approaches need explanation Yet forced labor gets no specific action guidance.  Recommended fix: Add application requirement or specific paragraph requiring disclosure of actions taken to prevent, identify, and remediate forced labor in value chains, consistent with the policy requirements already established in S2-1.  This addresses an obvious gap where EFRAG determined forced labor warranted policy disclosure but not action disclosure.","S2","Disclosure Requirement S2-3 - Actions and resources related to value chain workers",""]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Simplification of the Double Materiality Assessment is welcome. For smaller companies and value-chain actors, clear and practical guidance is essential. At the same time, maintaining comparability between companies is important so that DMA does not become too subjective."]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","Improved readability and use of summaries will help stakeholders who are not technical experts to access sustainability information. This is especially relevant for SMEs and service providers, who need ESG information in a concise format."]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","The reliefs, especially undue cost/effort and flexibility on data quality, are critical for companies indirectly impacted by CSRD, such as suppliers. They make the reporting more realistic without undermining transparency."]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Alignment with IFRS S1/S2 is essential for global companies and their supply chains. Enhancing interoperability reduces duplication of effort and supports international comparability."]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","The reduction of datapoints (-57% mandatory, -100% voluntary) is very positive. It reduces the burden for companies indirectly impacted by CSRD, while keeping the focus on material and useful information. This makes reporting more practical for SMEs and value-chain actors."]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","The amended ESRS strike a good balance between simplification and retaining the core objectives of the Green Deal. The substantial reduction of datapoints, improved clarity and readability, and elimination of voluntary disclosures make the standards more practical for companies indirectly impacted by CSRD, such as SMEs and value-chain partners. These changes will help reduce administrative burden while keeping reporting relevant and comparable for stakeholders."]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","United Media Services","Preparer (non-financial preparing a sustainability report)","Romania","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"As a company indirectly impacted by CSRD, we value the simplification process which makes sustainability reporting more achievable for SMEs and value-chain partners."]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","how to report' guidelines (methodology) and examples of possible items in structured way is very useful."]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","Allowing  an undertaking to report metrics with a partial scope of calculation is very helpful in reducing the administrative burden and effort."]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","SBM-3"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.E1.","Comments on deleted datapoints in ESRS E1","I agree","E1-9"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","E2-6"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","E3-5"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.E4.","Comments on deleted datapoints in ESRS E4","I agree","E4-6"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","E5-6"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CEZ","Preparer (non-financial preparing a sustainability report)","Czechia","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The rational to promot a reporting more close to the management view does not ensure progress on CSRD (29): \"The fitness check on corporate reporting shows that those two perspectives are often not well understood or applied. It is therefore necessary to clarify that undertakings should consider each materiality perspective in its own right\".   By merging and presenting information regarding IROs on topical level - and thereby mixing negative and positive impacts, risks and opportunities - the presentation of information specificially related to one of the two perspectives can be aggregated, netted and obscured. The suggested wording is intended to emphasize that aggregation is only allowed by type of IRO family, to avoid netted outcomes.  Also, the rationale for para. 66 is \"Clarify that materiality is assessed at IRO level\". It is then logical that all IROs cannot be merged into reporting on topic level only.  And in para. 113 it is stated that \"the undertaking shall make explicit which policies, actions and targets relate to which material impacts, risks, or opportunities, in accordance with paragraph 22\". It's not possible to map PATs to \"which material\" IROs, if they are all aggregated and presented only at topic level.   Suggested wording: \"Information shall be presented either for groups of negative impacts, positive impacts, risks or opportunities levels, or at individual negative impact, positive impact, risk or opportunity level, depending on\""]
["Survey","Cleerit","Consultant (including software vendor)","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The rationale to merged all provisions if the undertaking has not adopted PAT, will complicate reporting for companies managing on IRO or groups of IROs level. Very often there are actions but not articulated policies and targets for example. So the option to separate policies, actions and targets is needed."]
["Survey","Cleerit","Consultant (including software vendor)","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The obvious choice is Option 1 since this is a key information for investors, a key component of the Green Deal (to redirect capital) and a key prerequisite to help companies to increase awareness and resilience. Given the phase-in provisions, the option to report either single amounts or ranges (AR 18 for para. 23), and the possibility to explain why the information has not been provided, the burden is proportionate. In addition, there is now AR 15 for para. 23. In preparing disclosures about its anticipated financial effects, an undertaking shall use reasonable and supportable information available to it at the reporting date without undue cost or effort (see paragraphs 88, 89 and 90 of ESRS 1).  I disagree with the choice not to provide the option to state the  \"lack of skills\" as a reason to omit quantitative information. It would be better to let the preparer be transparent and provide the real reason. The explanation \"when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects\" could potentially be used too broadly and also disguise a lack of skills as a reason to omit quantitative information. Transparency would be enhanced if the two choices were provided and accounted for."]
["Survey","Cleerit","Consultant (including software vendor)","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Cleerit","Consultant (including software vendor)","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","The rationale to merged all provisions if the undertaking has not adopted PAT, will complicate reporting for companies managing on IRO or groups of IROs level. Very often there are actions but not articulated policies and targets for example. So the option to separate policies, actions and targets is needed.  34f, \"if relevant, whether and how the undertaking makes the policy available to potentially affected stakeholders, and stakeholders who need to help implement it\" should not be deleted. If an affected stakeholder is not able to understand if the policy is effectively communication, how can it consider that the policy can be respected? CSRD explicitly spells out that an accountability deficit could lead to lower levels of citizen trust in businesses, which in turn could have negative impacts on the efficient functioning of the social market economy (14), and that (18) disclosing on sustainability matters is justified by concerns about the impacts and accountability of the undertaking (18).  This information should not be deleted: \"(e) information regarding the progress of  key actions underway and disclosed in prior periods and, if relevant, key actions taken in the reporting year \". Not disclosing on progress, especially for policy goals and key actions without metrics (which is a very common scenario), would result in descreased accountability and increased risk of greenwashing. Just reporting action information, without referens to qualitative progress and/or success, does not give enough information. You can take action, but if the intended outcome is not there, information on the action is much less meaningful. The rationale to reduce granularity is not a priority for this information."]
["Survey","Cleerit","Consultant (including software vendor)","France","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Cleerit","Consultant (including software vendor)","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","It would be useful to add an explanation detailing the differences between a faire presentation and compliance reporting framework."]
["Survey","Cleerit","Consultant (including software vendor)","France","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","DMA should enable an explanation of where a topic is material to only 1 part of a company/market/subsidiary and then allow that topic to be 'limited' for disclosure and assurance purposes.  This is particularly important for 'social IROs' in S1 and S2. Example is retail employees being harassed by members of the public is a specific UK-only issue.  UK subsidiary is outside EU-owned parent and therefore while the reporting company can recognize the issue as material, it does not need to disclose as part of parent company report."]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","the explanation of the changes and the changes make the process more complex, not less!  if there is prior regulation/reporting requirements like for H&S, this should be excluded from CSRD not layered on top."]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","these changes will not help to streamline the audit process.  it is not apparent that the proposal will simplify the disclosure structure.  in E1 for example, there is no 'flow' for the narrative DPs - the DP numbering jumps from one aspect to another and back again.  It would be very helpful to show a structure for an ESRS statement which would clarify what the reporting company should state and what the auditor can expect to see.  We are interating this at present and it is very time intensive."]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Please create a checklist and flow chart to accompany the words - words are too open to interpretation"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","S1 has proved particularly problematic for HR teams to respond to.  The language used does not align with their current reporting requirements and other standards.  A lot could be done to address this."]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E1; S1; S2","ensure reference and language alignment to existing standards and regulations such as H&S, packaging disclosures, GRI, TCFD etc"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","These are very welcome, but still leave open some questions:  on point 7 (acquisitions/disposals relief) - how does that align with GHG protocol for carbon accounting and rebaselining?"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","a time limit will encourage continuous improvement, but it must be realistic for preparers to achieve"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","if investors are particularly concerned about the risk to their investment in a company, they can ask for private clarification"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","still many terms that need careful definition or reference to other standards and regulations ie critical and strategic raw materials"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","remains open to interpretation between the preparer and auditor"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","although more disclosure, the clarification is simpler"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","still way too complex!"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Communique","Consultant (including software vendor)","United Kingdom","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree",null,null,null,""]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Techko, spol. s r.o.","User (analyst, data provider, rating agency, etc.)","Czechia","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","Will need a time limit imposed for good practice ."]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","A lot of companys were not doing the voluntary declarations anyway"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","Water usage of key climate importance"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Micro plastics will be tricky to calculate putting a big burden on business"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Need full transparency"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","Don't fully understand what you are saying"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Salutary Ltd","Preparer (non-financial preparing a sustainability report)","Ireland","35.E3-3."," Do you agree with the amendments of this chapter? ","I disagree","Big burden on business","E3","Disclosure Requirement E3-3 - Targets related to water",""]
["Survey","University of Gdańsk","Academia","Poland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree"]
["Survey","University of Gdańsk","Academia","Poland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1"]
["Survey","University of Gdańsk","Academia","Poland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","University of Gdańsk","Academia","Poland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","University of Gdańsk","Academia","Poland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","University of Gdańsk","Academia","Poland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","University of Gdańsk","Academia","Poland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","University of Gdańsk","Academia","Poland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree"]
["Survey","University of Gdańsk","Academia","Poland","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Gdańsk","Academia","Poland","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","improvements: information materiality, granularity;"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","gross net not sufficiently clarified"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","positive that all AR are now part of the main body. but what is the purpose of the NMIG? And the relation to other Implementation Guidance? If there are important aspects, they should be part of the main document or be moved to specific IGs."]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Readiness of companies will be limited to provide quantification of financial effects, therefore option 2 to be preferred"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree",null,null,null,""]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Weight is not a meaningful metric especially for non-manufacturing companies"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","We would prefer the adjusted pay gap to be mandatory as it is more meaningful"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","gross/net still not fully clear"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","unclear what is meant with resilience analysis - better instruction needed"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","sector-specific guidance would be helpful"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","A1 Telekom Austria Group","Preparer (non-financial preparing a sustainability report)","Austria","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Augusto Cocchioni – Independent Strategic Advisor on Participatory Governance and Integrated Sustainability","Other - please specify (required)","Hungary","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"This contribution refers in particular to ESRS S1 – Own Workforce and ESRS 2 – GOV-1 (Governance), where indicators on workers' participation could be introduced.  I welcome EFRAG's effort to simplify the ESRS while preserving decision-useful information. However, a material imbalance remains between the environmental pillar (E) — rich in comparable KPIs — and the social pillar (S), where disclosures are largely process-oriented and narrative. In particular, the quality and effectiveness of workers' participation in governance and decision-making are not measured.  The CSRD already requires companies to inform and discuss sustainability information with workers' representatives, and to communicate their opinion to the relevant bodies (Article 19a(5) and Article 29a(6)). Italy's Legislative Decree 125/2024 mirrors this obligation (Article 3(7); Article 4(9)). It is therefore consistent to reflect this legal basis in the ESRS through proportionate, \"light\" indicators that do not increase burden but enhance the credibility of the social dimension.  I recommend adding to S1 and GOV-1 a minimal set of indicators, applicable \"if material\" and proportionate for SMEs (L-SME and VSME):  1. Participation in governance: presence of workers' representatives on administrative/supervisory bodies; % of seats held (where provided by national law).  2. Consultation on strategic decisions: % of strategic decisions (e.g., transition plans, ESG investments, restructurings) subject to prior consultation/information.  3. Social dialogue functioning: number of annual meetings with workers' representatives on ESG topics; existence of joint committees or agreements on sustainability governance.  4. Outcomes (voluntary for SMEs): changes in turnover, accidents, absenteeism, or disputes following participatory practices.  These indicators would keep simplification intact while ensuring a balanced S vs. E approach and better alignment with the CSRD's participatory spirit."]
["Survey","Augusto Cocchioni – Independent Strategic Advisor on Participatory Governance and Integrated Sustainability","Other - please specify (required)","Hungary","35.ESRS2_GOV-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","I recommend adding proportionate KPIs on workers' representation in boards or supervisory bodies, to align with CSRD Articles 19a(5) and 29a(6).","ESRS2","GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability",""]
["Survey","Augusto Cocchioni – Independent Strategic Advisor on Participatory Governance and Integrated Sustainability","Other - please specify (required)","Hungary","35.S1-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","S1-2 should go beyond describing engagement processes and also capture the effectiveness of workers' participation. I recommend introducing proportionate KPIs such as % of strategic decisions subject to consultation and number of annual ESG-related meetings with workers' representatives.   S1-7 covers bargaining coverage and social dialogue, but does not measure outcomes. I suggest adding light indicators (e.g. existence of joint committees on sustainability, outcomes in turnover, safety or absenteeism linked to participatory practices).","S1","Disclosure Requirement S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_BP-1."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","BP-1 - Basis for the preparation of the sustainability statement",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_BP-2."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","BP-2 - Specific information if the undertaking uses phasing-in options",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GOV-1."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GOV-2."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","GOV-2 - Integration of sustainability-related performance in incentive schemes",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GOV-3."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","GOV-3 - Statement on due diligence",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GOV-4."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","GOV-4 - Risk management and internal controls over sustainability reporting",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_SBM-1."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","SBM-1 - Strategy, business model and value chain",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_SBM-2."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","SBM-2 - Interests and views of stakeholders",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_SBM-3."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","SBM-3 - Interaction of material impacts risks and opportunities with strategy\nand business model, and financial effects",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_IRO-1."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_IRO-2."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GDR-PAMT."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","General Disclosure Requirements for Policies, Actions, Metrics and Targets",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GDR-P."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","General Disclosure Requirement for policies - GDR-P",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GDR-A."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","General Disclosure Requirement for actions and resources - GDR-A",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GDR-M."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","General Disclosure Requirement for metrics - GDR-M",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.ESRS2_GDR-T."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS2","General Disclosure Requirement for targets - GDR-T",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E1-4."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-4 - Policies related to climate change",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E1-5."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-5 - Actions and resources in relation to climate change",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E1-6."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-6 - Targets related to climate change",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E1-7."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-7 - Energy consumption and mix",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E3-1."," Do you agree with the amendments of this chapter? ","I agree",null,"E3","Disclosure Requirement E3-1 - Policies related to water",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E3-2."," Do you agree with the amendments of this chapter? ","I agree",null,"E3","Disclosure Requirement E3-2 - Actions and resources related to water",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E5-1."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-1 - Policies related to resource use and circular economy",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E5-2."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-2 - Actions and resources related to resource use and circular economy",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.E5-3."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-3 - Targets related to resource use and circular economy",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S1-1."," Do you agree with the amendments of this chapter? ","I agree",null,"S1","Disclosure Requirement S1-1 - Policies related to Own workforce",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S1-3."," Do you agree with the amendments of this chapter? ","I agree",null,"S1","Disclosure Requirement S1-3 - Actions and Resources related to Own workforce",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S1-4."," Do you agree with the amendments of this chapter? ","I agree",null,"S1","Disclosure Requirement S1-4 - Targets related to Own Workforce",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S3-1."," Do you agree with the amendments of this chapter? ","I agree",null,"S3","Disclosure Requirement S3-1 - Policies related to affected communities",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S3-2."," Do you agree with the amendments of this chapter? ","I agree",null,"S3","Disclosure Requirement S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S3-3."," Do you agree with the amendments of this chapter? ","I agree",null,"S3","Disclosure Requirement S3-3 - Actions and resources related to affected communities",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S3-4."," Do you agree with the amendments of this chapter? ","I agree",null,"S3","Disclosure Requirement S3-4 - Targets related to affected communities",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S4-1."," Do you agree with the amendments of this chapter? ","I agree",null,"S4","Disclosure Requirement S4-1 - Policies related to consumers and end-users",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S4-2."," Do you agree with the amendments of this chapter? ","I agree",null,"S4","Disclosure Requirement S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S4-3."," Do you agree with the amendments of this chapter? ","I agree",null,"S4","Disclosure Requirement S4-3 - Actions and resources related to consumers and end-users",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.S4-4."," Do you agree with the amendments of this chapter? ","I agree",null,"S4","Disclosure Requirement S4-4 - Targets related to consumers and end-users",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.G1-1."," Do you agree with the amendments of this chapter? ","I agree",null,"G1","Disclosure Requirement G1-1 - Policies related to business conduct",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.G1-3."," Do you agree with the amendments of this chapter? ","I agree",null,"G1","Disclosure Requirement G1-3 - Targets related to business conduct",""]
["Survey","emeis","Preparer (non-financial preparing a sustainability report)","France","35.G1-4."," Do you agree with the amendments of this chapter? ","I agree",null,"G1","Disclosure Requirement G1-4 - Metrics related to Incidents of corruption or bribery",""]
["Survey","Upright","User (analyst, data provider, rating agency, etc.)","Finland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The majority of the changes in Chapter 3 related to DMA are very welcome.  One potentially problematic point is the option to choose between bottom-up or top-down approaches:  While the bottom-up approach can be labor-intensive, it is fully feasible with modern technology. As one example, Upright's DMA data engine goes through all topics (prev. sust.matters) and identifies IROs using scientific articles without manual work. However, without such technology, the bottom-up approach may indeed be demanding.  On the other hand, the top-down approach carries risks. Companies may rely on quick, subjective judgments. For example, if value chain data is lacking and costly to obtain, a company might conclude that \"value chain topics probably do not result in material IROs.\" Such decisions reduce transparency and accuracy. Auditors may also struggle to challenge companies, since the top-down approach is allowed under current guidance.   This risk is further heightened when combined with the 'undue cost or effort' clause.  Balancing pros and cons (reduced workload vs. risk of poor-quality DMAs) and considering practical viewpoints, Upright suggests:  ESRS should require that, when using a top-down approach, companies need to gather sufficient evidence before deeming a topic non-material. Practical examples of what \"sufficient evidence\" could look like, without compromising too much on efficiency gains and reverting to the rebuttable presumption rule of the original ESRS draft:  1.Using available data, tools, technology, and proxies for a quick overview before excluding topics.  2.If there are any indications that a topic could be material, performing light spot checks before confirming non-materiality.  3.Explicitly stating that the 'undue cost or effort' clause cannot justify omitting IROs very likely to be material (e.g., by industry or geography). I.e., cannot serve as a means to conceal material IROs the company prefers not to disclose.  4.Longer-term: introduce sector-specific recommendations (see answer in \"Any other comments\")."]
["Survey","Upright","User (analyst, data provider, rating agency, etc.)","Finland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","From Upright's point of view, the new gross/net rule creates a reporting paradox that could mislead investors and other end-users of sustainability statements.  Identified problems: - Flawed comparability - Misleading risk perception - Skewed incentives - Lack of transparency   A straightforward \"gross basis for all\" approach would be far clearer and more useful for all stakeholders.  More details, please see: https://www.uprightproject.com/blog/upright-stance-on-esrs-draft/  GROSS VS. NET: ASSESSMENT OF COST-SAVINGS The gross vs. net issue has been unclear, creating extra work for reporters. Greater clarity would definitely bring cost savings.  In addition to the cost savings gained from increased clarity, some have argued that the latest recommendations in ESRS draft (gross/net approach) would also deliver significant cost reductions compared to Upright's proposed \"gross basis for all\" approach.   Upright's perspective differs: In practice, only a limited number of impacts would fall under the \"net\" category, where mitigation actions make them permanently non-material.  - Some environmental impacts might qualify, but for example potential human rights and governance impacts are unlikely to do so. This is partly because the \"severity takes precedence\" rule applies to negative human rights impacts.  - In addition, negative human rights impacts are often complex and occur deep in value chains, making permanent mitigation very difficult.   Overall, Upright believes there are very few cases where mitigation activities would make an issue non-material. In other words, the number of reporters who could significantly reduce their reporting workload because of this rule is small. This should, of course, be validated as part of EFRAG's ongoing gross vs. net discussions with reporters.  By contrast, clear and consistent rules would make reporting more straightforward and lead to cost savings — without the aforementioned downsides of the gross/net approach, which risks reducing overall reporting quality."]
["Survey","Upright","User (analyst, data provider, rating agency, etc.)","Finland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Upright","User (analyst, data provider, rating agency, etc.)","Finland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The inclusion of the 'undue cost or effort' relief is, in principle, a positive step, as it may help reduce overly demanding requirements such as some auditing expectations currently pushed onto companies. Alignment with IFRS principles is also welcome.  However, Upright is concerned that this relief could lower the quality of sustainability information if companies use it to justify subjective judgments, rather than evidence-based analysis. This risk grows when combined with the top-down approach: companies could declare top-down that a topic is not material without proper analysis and invoke 'undue cost or effort' to avoid scrutiny.  To prevent misuse of the clause—especially alongside the top-down approach—the amended ESRS could require sufficient evidence before concluding a topic is not material. Examples include:  1.Expanding the list of information always considered 'available without undue cost or effort': Unlike IFRS S1 (paragraph B9), ESRS does not include external sources. IFRS explicitly refers to 'generally available external sources such as peer benchmarks, ratings, or public statistics', but this is missing from ESRS. The framework could encourage use of such sources by stating that 'generally available sustainability data, tools, technology, and proxies' are considered available without undue cost or effort.  2.Explicitly prohibiting use of the clause to omit IROs very likely material given industry, geography, or stakeholder relevance. The clause must not be used to conceal material IROs a company prefers not to disclose.  3.Longer term: developing sector-specific guidance on likely material IROs (especially in value chains), reducing duplicate work and discouraging purely subjective judgments (see Upright's answer in \"Any other comments\").  In summary, these clarifications would preserve the efficiency benefits of the 'undue cost or effort' principle while ensuring it does not become a loophole that undermines the reliability and comparability of ESRS disclosures."]
["Survey","Upright","User (analyst, data provider, rating agency, etc.)","Finland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Upright strongly supports Option 1: it is the only approach that maintains comparability between companies, secures alignment with global standards, and preserves credibility and decision-usefulness of CSRD for capital markets.  Option 1 is substantially aligned with IFRS S1 and S2, which establish the global baseline for sustainability-related financial disclosures, and with similar requirements adopted in California's SB-261 and Australia's new climate disclosure law.   While we understand that purely qualitative disclosures under Option 2 may ease some short-term challenges for companies, this temporary convenience comes at significant long-term cost to the credibility and utility of the CSRD:  1.Lack of efficiency for investors: Purely qualitative disclosures signal that management has not, or cannot, assess the financial consequences of sustainability-related financial risks and opportunities. This would critically diminish the usefulness of CSRD disclosures.  2.Loss of interoperability: Option 2 would create misalignment with IFRS and other global disclosure standards. This would force multinational companies to produce inconsistent reports for different jurisdictions - quantitative disclosures elsewhere and qualitative-only reporting under ESRS - thereby undermining the usefulness and credibility of the ESRS compared to other standards.  3.No incentives for progress: The main argument for Option 2 ignores the fact that this also removes the critical incentive to build more mature methodologies and reporting practices.   4.Mitigation plans require quantification: ESRS already requires companies to disclose their mitigation and adaptation strategies. Yet without quantitative financial effects, such disclosures risk being aspirational narratives rather than decision-useful information. Investors need to see whether actions materially reduce financial risks.  Many major jurisdictions (UK, Australia, Canada, Japan, China, Brazil, Mexico, Singapore, California) are adopting ISSB standards (IFRS S1 and S2), which require both qualitative and quantitative disclosure of anticipated financial effects. If the EU adopts Option 2 instead, it risks disconnecting from global developments and weakening its credibility in sustainable finance."]
["Survey","Upright","User (analyst, data provider, rating agency, etc.)","Finland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"SUGGESTIONS RELATED TO SECTOR-SPECIFIC IROs:   Upright recognizes that developing sector-specific standards is not currently on the agenda. However, Upright wishes to comment on longer-term plans, as the absence of sector standards creates challenges for both information quality and reporting efficiency:  1.Reporting quality: If companies define their own methodologies and thresholds, material IROs will vary widely among similar companies, undermining comparability and credibility.  2.Reporting efficiency: Companies with similar IROs conduct overlapping assessments in isolation, wasting time and resources.  Upright's suggestion is not to introduce sector-specific standards as originally planned, but rather a lighter version: sector-specific topic recommendations.  Providing sector-specific recommendations for topics, which can likely include material IROs (especially those related to value chains) could lead to efficiency improvements in the DMA process and ensure more comparable reports. When DMA is done properly for one company and its value chains, this information is often also very useful for other companies operating in the same industry and can significantly reduce their DMA workload.  Sector-specific recommendations would also reduce the risk of companies making subjective, sloppy decisions when deciding on material topics – a problem that arises with the 'top-down approach' and the 'undue cost or effort' clause.   -Companies can more efficiently set aside topics that sector recommendations indicate are typically not material, avoiding unnecessary analysis and effort, since the likelihood of material IROs in these topics is low.  -Conversely, companies cannot dismiss topics flagged by sector recommendations as likely material—they must still conduct an assessment before deciding otherwise.  For further details, see Upright's feedback on the 'top-down approach' and 'undue cost or effort' clause.  DMA data providers can support sector-specific recommendations. For example, Upright's data on 50,000+ companies can generate sector-specific heatmaps, which Upright is willing to share free of charge to support regulatory development and supervision."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Overall, I find the section to be much clearer compared to the earlier drafts, with several important improvements. The simplified list of topics and subtopics, as well as the clarification between bottom-up and top-down approaches, are very useful. The annex explaining how to treat impacts when mitigation or remediation measures are applied is also a strong addition. This resolves a frequent doubt among companies that questioned whether implementing such measures should reduce severity scores.  However, I see some remaining gaps. In my view, it is problematic that the text suggests companies do not need to investigate further if they lack immediate information about impacts across time horizons. This is risky, as an impact that may appear irrelevant in the short term could become highly material in the medium or long term. Companies should be and educated to consider these dynamics rather than being given the impression they can skip deeper analysis. Another issue is that, while the overall text is clearer, the main challenge was never just ambiguity. The real problem is that many companies, including some of the largest in the Romanian market, do not understand concepts like forecasts or scenario analysis. While the standards have added examples in several places, it would be very helpful if the double materiality module also included simple, practical examples of these concepts. This would improve accessibility and reduce dependence on consultants or auditors, who often apply inconsistent methodologies.  From my perspective, the standards themselves were not the main obstacle, even in the first drafts. The issue was the lack of a general methodology and a lack of references to practical resources (for instance, pointing companies towards UN Compass or similar tools)."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","I fully agree that the additional clarifications were needed. While the text may seem overwhelming at first glance, the accompanying table is a very important and useful addition.  I would also like to emphasize that companies should not refrain from reporting an impact simply because they are very careful in managing it. From my experience working with companies in heavy industries such as petroleum and coal, I have seen that many invest heavily in renewables, seek to transform their business models, or maintain very high safety standards (for example, ensuring pipelines are well maintained to avoid spills, which are among the main risks in the sector).  However, even with strong prevention or mitigation measures, a potential impact still exists. This is inherent to the activity of the industry. For this reason, impacts should be reported transparently, alongside the measures undertaken to remediate or prevent them. Otherwise, there is a risk that companies may conclude that their prevention efforts are so effective that the underlying topic is no longer worth reporting. In my view, this would be a mistake and should be avoided through clearer guidance."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The only point I do not agree with is the removal of the requirement for a designated person or authority within the company to be responsible for implementing policies and driving change. In my view, this diminishes the sense of accountability within companies.  I do understand that, for companies with no existing plans or interest, it would have been very difficult to map a clear timeline for future actions. However, eliminating the requirement for undertakings to plan and implement pathways for material topics and timelines is not a good development. Impacts are always linked to broader topics, and without this responsibility and forward-looking planning, the connection between identified impacts and the company's strategic response becomes much weaker.  That said, I agree with the clarifications on aggregation level. Regarding the connections with GOV, SBM, and IRO, I cannot comment, as my work focused exclusively on the environmental side."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E1; E2; E3; E4; E5","I believe the standards should include as many practical examples and references as possible. This is crucial in markets where sustainability is still emerging and companies often lack even a dedicated sustainability department. From my experience, many large companies simply do not understand what is being asked of them. Without guidance, they see requirements but cannot translate them into action.  References to existing frameworks and tools would make the standards more usable. For example, the European Pollutant Release and Transfer Register, Natura 2000 maps, biodiversity-sensitive zones, and air quality maps could help companies assess whether their activities add pressure to already vulnerable environments. Linking to relevant legislation on pollution or international biodiversity conventions would also provide clear direction.  This should not be seen as additional effort for companies but as guidance. For instance, when asked to describe eco-design or circular initiatives, many companies do not even understand the concept. If presented with examples, case studies, or graphical tables, they would have a concrete starting point.  Clearer definitions are also needed. For example, \"biological materials\" should be explicitly defined in ESRS E5. In practice, I have seen debates where companies and auditors applied different interpretations, leading to unnecessary conflicts. Consistency in definitions would greatly reduce such issues.  Finally, the standards should link more strongly with systems and obligations that companies already have in place. In my work, I often extracted actions and targets directly from environmental permits when dealing with air pollution as a material topic. Referencing such sources grounds reporting in the real world and reduces reliance on consultants.  In short, the problem was never the depth of the standards, but the lack of practical connections. Stronger references, definitions, and examples would make them both clearer and more impactful."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","From my perspective, it is not acceptable to suggest that no reliable or direct estimated data can be used in calculations. There are always methods available—geographical proxies, industrial proxies, peer proxies—that can provide reasonable estimates. It is far better to work with estimated data than to have no data at all.  Expanding this flexibility to the value chain creates an even bigger problem. If companies are allowed to claim that data is not available, it gives them a window of opportunity to reduce their efforts further. This undermines comparability and diminishes the purpose of the directive itself. At least with estimated data, results can be benchmarked and compared across undertakings. But if companies report partial data from different sources, without consistent estimation, the reliability and usefulness of the disclosures is severely weakened.  I also believe that removing time limits on data collection makes this situation worse. If sustainability declarations are to have real value, beyond narratives about investments and initiatives, they must be grounded in robust data. Numbers are the cornerstone of these reports. They provide the evidence base for assessing progress and ensuring accountability.  For this reason, data collection should be treated as the highest priority. Instead of allowing companies to bypass this responsibility, they should be better instructed and equipped with clear sources from which to obtain the necessary data. Practical guidance, examples of proxies, and references to databases would all support companies in fulfilling this requirement without excessive burden."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","I do not agree with the idea that companies should be allowed to omit quantitative projections of anticipated financial effects simply because they lack resources, nor that such projections should be reported only on a voluntary basis. While I acknowledge that there is very high uncertainty in these estimates, and that no unified methodology currently exists, I fully support Opinion 1: quantitative information, even when estimated, is better than relying only on qualitative disclosures.  Uncertainty is an inherent part of projections, but this does not make them less valuable. Even imperfect estimates provide a basis for comparison across companies and sectors, and allow investors to assess exposure to risks and opportunities in a structured way. By contrast, qualitative information alone does not enable standardization or comparability. Narrative disclosures may describe risks or impacts, but without numbers, investors cannot evaluate their magnitude or determine whether to continue investing.  Permitting companies to omit quantitative projections on the grounds of limited resources creates perverse incentives. It could encourage undertakings, especially in more complex value chains, to avoid making the effort to provide meaningful financial insights. At least with estimates—whether based on geographical, industrial, or peer proxies—there is some level of comparability and benchmarking. Without them, reporting risks becoming fragmented and inconsistent, undermining the purpose of the directive.  The credibility of sustainability declarations relies on more than stories of initiatives or commitments. The real value lies in the numbers—financial data and projections that demonstrate the scale of impacts and risks. Companies should be supported with clear methodologies, proxy examples, and references to data sources, but not given the option to bypass quantitative reporting altogether."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","In my view, the current approach places less emphasis on resilience and instead focuses primarily on risks—the negative side of the equation. While this may appear unbalanced, I believe the provision is clear enough and provides investors with a safe buffer zone. Ultimately, the priority is to ensure that investors can adequately assess potential vulnerabilities and exposures, and this framing achieves that objective.",null,null,""]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","I fully support the efforts to harmonize standards and set uniform boundaries, particularly with respect to the financial control approach. This type of alignment is important for comparability and consistency across companies and sectors. However, there are two key points on which I strongly disagree.  First, companies should not be allowed to omit Scope 3 emissions from their reporting. In many sectors, Scope 3 emissions represent the overwhelming majority of the footprint—often 85–90%. Excluding them would mean ignoring the most material part of a company's impact, which undermines both the credibility and the purpose of the directive. These are not small or under-resourced undertakings; we are speaking about some of the largest companies in Europe and globally, with the capacity and resources to measure and report these emissions. For them, Scope 3 should not be optional.  Second, I strongly disagree with the idea that companies may omit quantification of potential financial effects when they claim to lack the necessary skills. Who decides whether they have the required skills or not? It is not realistic to assume that any company within the scope of this directive truly lacks the resources to either build this capacity internally or obtain it externally. Allowing such exemptions creates a dangerous precedent and weakens accountability."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","Nothing to add."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","Fair, especially the unknown waste trajectory one."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Exactly the point of masking rising emissions, both relative and absolute emissions should be considered."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I would like to skip this question and provide my feedback in Part 3","My expertise only spans E."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","My expertise only spans E."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","My expertise only spans E."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","My expertise only spans E."]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dublamaterialitate.ro/ Sustainability lens","Consultant (including software vendor)","Romania","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Simplification is enough to allow more easily allow entities to meet requirements without further watering down."]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","May is ridiculous- shall is intent"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Financial institutions have a significant responsibility to both lead and understand their role so that they are in a position to model strategies that will have  positive levers for other stakeholders and set a standard across all industries and investments"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Irish Trees ","Other - please specify (required)","Ireland","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","with proposed changes achieving the objectives of the EU Green Deal will not be possible"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree",null,null,null,""]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Subtopics \"Drivers of biodiversity and ecosystem change\" and \"The extent and condition of terrestrial and marine ecosystems\" still seem to overlap, or further clarification on what each of the sub-topics comprises would be necessary"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Combination of S1 and S2 is questionable"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Combination of S1 and S2 is questionable"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Alpiq AG","Preparer (non-financial preparing a sustainability report)","Switzerland","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","CEWEP","Business association (other than association of financial institution)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The recovery definition proposed in Annex II p. 27 and its application to ESRS E5, paragraph 18 on waste, do not align with existing EU legislation. The Waste Framework Directive (2008/98/EC, Article 3(15) and Annex II), which is the cornerstone of EU waste management legislation, defines recovery as:  \"any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy. Annex II sets out a non-exhaustive list of recovery operations.\"  As currently drafted, the reporting framework would lead to inaccurate reporting, as it would be unclear where to report incineration with energy recovery (R1): it is explicitly excluded from the ESRS definition of \"recovery\", but is not a disposal operation and therefore should not be reported under \"waste directed to disposal\". This would misrepresent actual waste treatment performance, create inconsistencies in EU statistics and compliance reporting, and result in incorrect financial disclosures by companies, since waste treatment pathways directly affect cost allocations, liabilities, and sustainability performance indicators.     The stated goal of the Amended ESRS consultation is simplification and greater usability without compromising EU objectives. Introducing a definition that conflicts with existing law instead increases reporting complexity, as companies would face two contradictory classifications.  To ensure alignment with existing EU legislation and avoid unnecessary burdens, we propose that:  ·                 The definition of \"recovery\" in Annex II should be amended to replicate or explicitly reference the definition provided in Article 3(15) of the Waste Framework Directive.  ·                 ESRS E5 §18 should clearly reflect that incineration with energy recovery (R1) is a recovery operation, consistent with EU law. For example, \"iii. other recovery operation, including incineration with energy recovery\""]
["Survey","CEWEP","Business association (other than association of financial institution)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The recovery definition proposed in Annex II p. 27 and its application to ESRS E5, paragraph 18 on waste, do not align with existing EU legislation. The Waste Framework Directive (2008/98/EC, Article 3(15) and Annex II), which is the cornerstone of EU waste management legislation, defines recovery as:  \"any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy. Annex II sets out a non-exhaustive list of recovery operations.\"  As currently drafted, the reporting framework would lead to inaccurate reporting, as it would be unclear where to report incineration with energy recovery (R1): it is explicitly excluded from the ESRS definition of \"recovery\", but is not a disposal operation and therefore should not be reported under \"waste directed to disposal\". This would misrepresent actual waste treatment performance, create inconsistencies in EU statistics and compliance reporting, and result in incorrect financial disclosures by companies, since waste treatment pathways directly affect cost allocations, liabilities, and sustainability performance indicators.     The stated goal of the Amended ESRS consultation is simplification and greater usability without compromising EU objectives. Introducing a definition that conflicts with existing law instead increases reporting complexity, as companies would face two contradictory classifications.  To ensure alignment with existing EU legislation and avoid unnecessary burdens, we propose that:  ·                 The definition of \"recovery\" in Annex II should be amended to replicate or explicitly reference the definition provided in Article 3(15) of the Waste Framework Directive."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Concerning Appendix C, \"If the potential impact was material within the reporting year, but prevention or mitigation action has been taken before the reporting date such that the impact no longer exists\", The user does not benefit from the information, if the impact no longer exists, the mitigation action was taken beforehand. Therefore, it is not necessary to report the potential impact. It also raises the question, whether the statement contradicts Paragraph 34, which states that \"the severity of the impact shall be evaluated considering the outcomes of any mitigation or prevention measures implemented before the impact occurred\"."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","Explicitly mentioning the option of including an 'executive summary' putting detailed information in the appendices increases audit reliability. However, we have already assumed that this flexibility is given according to the former version. Therefore, there is now a risk that only explicitly stated presentation options are permissible."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The level of simplification of the minimum disclosure requirements is not significant and continues to limit the reporting options. Since the PATs form the core of the CSRD, a large portion of the report remains almost unchanged. Further simplification could be achieved by reclassification some of the minimum disclosure requirements as application requirements."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","The NMIGS's explanations are generally very helpful for understanding the disclosure requirements and the idea behind. However, there is a risk that these guidelines will be interpreted by auditors as a kind of checklist which could even limit the adjustability to company specific content."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","Relief for lack of data quality on metrics (ESRS 1 paragraph 92)"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","All material sustainability risks can and must be reported in the risk report of the financial statements. Separate reporting in the non-financial section is redundant."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","40d: It is more logical and beneficial to evaluate the monetary amount and percentage of revenue at material physical risk after considering climate change adaptation actions. Evaluating risks before adaptation actions creates unnecessary alarm, misrepresents the company's actual vulnerability, and undermines the value of proactive climate resilience strategies. 41d: All reporting should follow accounting recognition criteria, across financial and non-financial reporting. 42: Users don't benefit from this information.",null,null,""]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Setting absolute targets for financial institutions can lead to wrong incentives, as every investment leads to additional emissions, even and especially when financing green technologies. This contradicts the Green Deal's primary goal of redirecting financial flows. By reporting the mandatory absolute Green house emissions as a simple metric, which is not a target, the required transparency is given."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","We cannot assess the complexity of this topic and rely on the results of the proposed field test."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","Investors can and in practice already do address their individual requirements to their investees bilaterally. There is no need for covering the SFDR requirements in a general regulatory approach."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","Companies with significant environmental impacts should inform themselves about the current state of scientific knowledge. This is not a regulatory task."]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Stadtwerke München GmbH","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","We believe that the new guidelines in ESRS 1 provide much-needed clarification on the treatment of remedial, mitigating, and preventive actions in the DMA process. The clear distinction between \"actual\" and \"potential\" impacts and the guidance on how to report measures already implemented facilitate assessment and make reports more comparable. We also appreciate the distinction between the current period and future reporting periods. This makes it easier to avoid duplication of information on previous impacts while maintaining consistency with policies and actions that are still in force. An important simplification is the indication that impacts are assessed before mitigation measures are taken, and only then are the implemented measures reported. This approach increases transparency, especially in regulated areas (e.g., health and safety). We agree that a \"gross\" approach (not taking actions into account) could lead to excessive reporting. The current solution seems to strike a good balance between transparency and the practical usefulness of reports. We also believe that it would be a good idea to link the list of material topics to the relevant disclosure points, which would further simplify the process and improve the consistency of reporting. Translated with DeepL.com (free version)"]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","We agree that the new guidelines in ESRS 1 clearly show how to take corrective, mitigating, and preventive measures into account when assessing the materiality of negative impacts. This makes reporting more transparent—it shows both the actual impacts before the measures were taken and the measures taken to mitigate or remedy them."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We agree that the changes improve the readability and consistency of sustainability statements, and that the option to use summaries and appendices—which we consider a good solution—helps separate key messages from detailed information, eliminating fragmentation and repetition of data."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","The changes in ESRS 2 are positive because they have simplified reporting, reduced the number of mandatory data points (\"shall\") and introduced greater flexibility in disclosure. We also like the ability to aggregate data and better link disclosures to relevant topics, which makes reporting easier and the information more readable and practical"]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We agree that the changes improve the clarity and readability of the standards. We like that all mandatory data points are clearly highlighted in the main body of the standard, and optional \"may disclose\" items have been removed. This makes it easier to understand exactly what needs to be reported."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We believe that NMIG is a useful supporting tool because it contains guidelines and examples that can facilitate reporting and reduce the number of questions regarding implementation. We appreciate that the content of NMIG is clearly marked as non-mandatory, which allows for flexibility and does not impose additional requirements on reporting entities. In our view, NMIG can support the practical application of standards, provided that it remains a supporting tool and not a mandatory requirement."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","We like the possibility of using estimates instead of direct data, limiting disclosure in the absence of quality data, and relief in calculating indicators. Such solutions reduce the workload and facilitate ESG reporting. We would like to ask for clarification of the relief in the form of \"unreasonable costs or effort\" – what exactly does this mean? For example, it could be specified that this refers to the additional working time needed for detailed analyses, the need to use consulting services, or other activities that cause a disproportionate burden in relation to the value of the information obtained. It would be worth considering clarifying in which specific cases the exemption can be used in order to facilitate practical application and reduce the risk of disputes during audits."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We believe that the relief for poor data quality is practical and necessary, as it allows metrics to be reported even with partial data coverage, thereby reducing the reporting burden. We like the fact that companies must simultaneously disclose measures to improve data quality in future periods, which encourages systematic improvement in data coverage. One drawback may be the need to justify the use of the relief to an auditor, so it would be useful to clarify in which situations it can be used."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","We favor option 2 because it makes reporting qualitative information mandatory, while leaving quantitative information voluntary for companies. We believe that this approach reduces the reporting burden and provides flexibility for topics where mature methodologies or reliable data are lacking. At the same time, option 2 allows companies to gradually develop their own methodologies and report quantitative data where available, without imposing rigid and difficult-to-meet requirements."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","We believe that the revised paragraphs 40, 41, and 42 of ESRS E1 have been sufficiently simplified. The remaining data points cover only information that is relevant to investors and lenders, striking a balance between reporting effort and user needs. We consider this approach to be practical and feasible for day-to-day ESG reporting",null,null,""]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","We view the changes to the PAT positively. The removal of less relevant, narrative data points and the transfer of mandatory requirements to the main part of the standard significantly simplifies reporting, while retaining the information that is key to assessing ESG materiality and impacts. A flexible, principles-based approach facilitates report preparation and reduces duplication of information, which is practical for companies."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","Even if the number of exceptions is small, changing the status from \"may\" to \"must\" introduces additional obligations and the risk of divergent interpretations. The principle of simplification should be applied consistently—each exception weakens its transparency and increases the burden on companies. In practice, this means more work in analyzing materiality and verification by auditors, which is contrary to the goal of reducing obligations."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","Adding new data points runs counter to the principle of simplification, even if there are only a few of them. Each exception means an additional obligation and increases the risk of ambiguous interpretation. Instead of improving transparency, this leads to greater burdens and undermines confidence in the very idea of simplification."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","The requirement for fair presentation in the ESRS is reasonable and may contribute to more relevant and transparent reporting by focusing on key information and reducing excessive disclosures. This ensures better use of the materiality filter and consistency of information for report recipients. At the same time, it is worth noting that the implementation of this requirement may increase audit requirements, as auditors will need to verify that the omitted data points are indeed not material, which may increase costs and legal risks. Overall, however, the change promotes the quality of reporting with an acceptable level of additional burden."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","I disagree – Disclosing both intensity targets and absolute emissions allows for a more complete understanding of the actual climate impact of financial institutions. Although absolute calculations may require additional assumptions and be more complex, they provide key information about total emissions that is not apparent from intensity targets alone. Exempting financial institutions could lead to unequal treatment of sectors and make it difficult to assess their actual role in the climate transition."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","I agree – The way SFDR PAI has been incorporated into the revised ESRS is clear and logical. Removing data points that overlapped with others or were practically irrelevant improves the clarity of reporting without losing important information. The consolidation of social standards indicators increases consistency and facilitates data interpretation, while not adversely affecting the scope of disclosures. These changes make reporting more understandable and focused on key ESG issues, with minimal risk of losing information that is relevant to investors and stakeholders."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","\"I partly agree and partly disagree\" – because AR 26 provides a solid foundation, but it is worth updating it to better reflect current scientific trends and requirements for evidence-based targets."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","I agree with the removal of the voluntary data point on the adjusted gender pay gap, as this simplifies the reporting process and reduces the workload for the departments reporting this data"]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","I agree – Removing the detailed indicator of the average invoice payment period is justified, as this data is often difficult to capture unambiguously and can lead to misleading interpretations. Retaining information on standard payment terms, the percentage of payments made on time, and any legal proceedings provides sufficient transparency and better reflects the company's payment practices towards SMEs."]
["Survey","SANOK RUBBER COMPANY S.A.","Preparer (non-financial preparing a sustainability report)","Poland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"I agree – The revised ESRS strike the right balance between reducing reporting burdens and preserving the content necessary to achieve the objectives of the European Green Deal. The simplifications improve the clarity and consistency of the standards, while reducing the number of data points that were difficult to implement in practice or duplicated other requirements. These changes will make it easier for companies to report effectively, while maintaining a high level of transparency and reliability of disclosures."]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Do we really preserve the transparency needed to achieve objectives of the Green Deal? Worried about that."]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We agree about the 5 above mentioned modifications."]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","Fully agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Cadeler","Preparer (non-financial preparing a sustainability report)","Denmark","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","There is some value on adjusted gender pay gap as well to reflect some business specifities."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The DMA should remain a principles-led process, enabling the application of contextual judgment and supporting a meaningful connection between an undertaking's strategy and its sustainability reporting. The simplifications of the DMA process mainly reduce the effort for wave 2 companies but will not significantly reduce the effort for companies that are already reporting according to ESRS.  Positive aspects: • Materiality filter: Stronger focus on materiality significantly reduces the reporting burden, adds more clarity. • DMA flexibility:  Both bottom-up and top-down approaches allow practical implementation. • Fair presentation: Emphasis on fair presentation rather than a checklist helps avoid excessive documentation. • Streamlined topic list lowers complexity and risk of overreporting. • Clarity on sub-topics: AR 21 / para. 50 provides decisive clarification that only material sub-topics need to be reported. • Documentation relief: Excluding DMAs for obviously (non-)material topics and consolidating sub-sub-topics further reduces effort. • Link to IROs: Clearer connection between IROs (Impacts, Risks, Opportunities) and topics improves usability.  Remaining concerns: • Materiality thresholds: Allowing thresholds is positive, but inconsistent approaches across companies are likely; the practical application of bottom-up vs. top-down remains unclear. • Appendix A: o AR 16 should be clearly communicated as \"Appendix A.\" o Adding topics (e.g. \"water storage\") contradicts simplification. o Merging S1 and S2 is problematic, as S1 is far more often material than S2. o Sub-topics remain overly detailed in places; further simplification would be desirable. • Risk analysis linkage: In some cases, results of risk analysis cannot be clearly reconciled with reporting requirements, as sub-topics do not always map neatly. • There still seems to be room for interpretation which will result in discussions with auditors. • Clearer information of when an information is \"necessary\"."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","We acknowledge that new Paragraphs provide helpful clarifications, but significant concerns remain about complexity and feasibility in practice. We recommend greater flexibility, clearer alignment with existing standards, and stronger recognition of regulatory compliance as a key driver of sustainability.  Positive aspects: • The guidance on distinguishing actual vs. potential impacts is useful and welcomed. • The clarification that remediation measures may be considered when assessing risks is a positive step, as it may reduce material risks and the related reporting effort. • Allowing consideration of actions that reduce the severity or likelihood of potential negative impacts reflects company practice and is in line with established risk management approaches.  Concerns and challenges: • The gross approach for potential impacts with ongoing mitigation may lead to overreporting. • The guidance adds significant complexity to the DMA process, especially for smaller or less mature reporters. Current software tools cannot meaningfully map these requirements, creating practical difficulties for companies and auditors. • Appendix C attempts to address the gross vs. net issue, but in practice it requires companies to assess each negative impact in detail. This is unlikely to simplify reporting and may not be feasible beyond manual solutions. • We suggest greater flexibility by allowing net risk approaches, similar to ISO norms (e.g. ISO 9001/14001), where the effectiveness of actions and controls is integrated directly into risk assessments.  Further considerations: • Excluding compliance with legal and regulatory requirements as a \"positive impact\" risks undervaluing the strategic role of regulation. • It is unclear whether globally valid guidelines remain acceptable as a mitigating factor under ESRS 1.36. • Unclear, when a mitigation or prevention action is considered \"significant\" and when would such action not be considered as significant? • Companies would have to report a high number of potential negative impacts (although non-material)"]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We agree that the proposed Amendments, in combination with other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting and enhance connectivity with corporate reporting.  Positive aspects: • Executive summary & appendices: The explicit option to provide an executive summary and use appendices (e.g. for taxonomy data) improves clarity, structure, and readability of reports. • Flexibility: The amendments reduce unnecessary detail in the main report and allow companies to focus on key messages, avoiding duplication and fragmentation. • Connected information: Clearer guidance strengthens connectivity with other elements of corporate reporting and avoids repetitive disclosures. • GDRs: The adapted logic for presenting GDRs (general disclosures) is seen as very positive. It allows GDRs at topic level, summarized for certain IROs or for individual IROs, with flexibility to adjust the level of detail to company-specific circumstances. This should be maintained. • Governance standard (ESRS-G): The restructuring and summarization of data points (e.g. G1-2 qualitative vs. G1-4 quantitative) provides for more concise and practical reporting.  Remaining concerns / open questions: • However, we understand these changes primarily as clarifications of existing options rather than substantial simplifications. From our perspective, they do not result in significant relief in terms of implementation effort or reporting complexity. • PAT duplication: The need to avoid duplication in the Performance and Target (PAT) section must be consistently recognized in the design of disclosure requirements. • Climate methodology (ESRS E1 AR 5, para. 18): It is unclear whether companies are expected to conduct a climate scenario analysis when disclosing the methodology used to assess the impact of hazards and transition risks. Greater clarity is needed."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We consider the proposed amendments under Level 3 to be a significant improvement. The restructuring of the architecture and the clarified interaction between ESRS 2 and the topical standards enhance the overall readability and usability of the standards. The reduction in prescriptive elements is seen as a major improvement.  Positive aspects: • Simplification. • Clear reduction of \"shall\" requirements in PAT lowers complexity and workload. • Deletion of topical specifications in GOV, SBM, and IRO simplifies the structure without major content loss; there should be no exceptions to this deletion. • Shortened standards and avoidance of duplication are highly welcomed. • Listing ARs directly after DRs improves readability and structure. Flexibility & pragmatism: • The new \"undue cost or effort\" clause is very positive, allowing companies to gradually expand databases without disproportionate burden. • Aggregation options reflect real management practice and increase efficiency. • Improved linkage between PAT and IROs enhances consistency and usability. • Absence of timeline explanations avoids unnecessary rigidity.  Remaining concerns: • Sub-topic clarity: o Risk analysis results cannot always be clearly reconciled with reportable content; sub-topics should be reflected more explicitly in the topical standards or in a clear mapping table of DRs to sub-topics. o Some combinations (e.g. anti-corruption & bribery with animal welfare and complaints procedures) appear inconsistent and should be corrected (notably in G1). • Scenario/resilience analyses (ESRS E1): It must remain permissible to report that such analyses are not conducted; companies should not be indirectly obliged. • Phase-ins and NMiGs: Data points with planned phase-ins should be omitted or voluntary. NMiGs must remain voluntary in practice, with no indirect obligation created. • Formulation of PAT: Reformulating PAT as ARs risks confusion rather than simplification. • the treatment of net versus gross risk complicating implementation rather than easing it."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We generally agree that the proposed amendments significantly improve clarity and accessibility of the ESRS. The changes make it easier for companies to identify mandatory content and apply the standards consistently. The revised layout—particularly the relocation of mandatory Application Requirements directly under the relevant Disclosure Requirements—makes the legal text easier to follow and reduces the need to navigate back and forth within the document. However, while the structure and readability have improved, the overall reporting requirements remain largely unchanged. As such, the simplification primarily supports better orientation within the standards rather than reducing the reporting burden itself.  Positive aspects: • Removal of \"may disclose\" provisions: Eliminating these optional elements improves clarity, avoids confusion, and ensures a clearer distinction between mandatory and voluntary disclosures. • Structure and usability: Relocating mandatory ARs under their related DRs enhances readability and transparency. • Language improvements: Revised wording supports better understanding and fosters consistent application across companies. • Transparency: The clearer separation of mandatory and voluntary requirements increases accessibility for both preparers and users of sustainability reports. • Simplification: The removal of duplicate data requirements, the shortening of standards, and the exclusion of non-mandatory data points from the NMiG make it easier to determine reporting obligations.  Remaining concerns: • E2-19 vs. AR7 scope: There is still a lack of clarity regarding whether disclosures should cover only Substances of Very High Concern (SVHCs) or also Substances of Concern (SoCs). Alignment is needed to avoid inconsistent interpretations and reporting burdens. • It is still unclear what is meant by \"policies\" - a definition would be helpful. Is it really just \"policy\" in the narrower sense or also a strategy that may only be documented internally? • Clarification needed: how to comply with 1.5°C goal of Paris Agreement • The texts are still very complex."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Eliminate the Non-Mandatory Implementation Guidance (NMIG) to avoid implicit obligations under a non-mandatory status. If retained, it must remain outside the Delegated Act.  The separation of mandatory and non-mandatory content improves the structure and readability of the standards. To ensure legal certainty and practical usability, the NMIG should remain outside the delegated act and its non-mandatory nature must be consistently emphasized. NMIG can serve as an orientation tool—especially for preparers in the early stages of implementation. However, it is important that the non-binding nature of NMIG remains clearly communicated and consistently understood by both preparers and auditors. There should be no implicit expectation that the examples provided must be followed or justified if not applied.  Positive aspects: • We support that non-mandatory data points have been moved to NMIG, ensuring that the ESRS itself focuses strictly on mandatory content. • The NMIG can provide helpful illustrative examples that support understanding and application without creating additional obligations.  Key conditions: • Legal status: The NMIG's non-binding nature must be clarified as soon as possible. It must not become a de facto \"state of the art\" that auditors, regulators, or stakeholders expect companies to follow. • Separation from ESRS: To avoid confusion, NMIG should remain clearly separate from the mandatory ESRS. Companies must be able to fulfill all reporting obligations by following ESRS alone. • No negative consequences: Non-compliance with NMIG must not result in disadvantages or be interpreted as a lack of compliance with ESRS.  Practical considerations: • While some members note that aligning NMIG references directly next to the related ESRS paragraphs could improve usability, this is not essential as long as the distinction between binding and non-binding content is preserved."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The interoperability with the ISSB framework should be more focused. It is not clear, why there are 23 continued differences, 30 new differences, and only 3 new areas of alignment identified by the ISSB. This would support a more proportionate and pragmatic implementation of the ESRS, without compromising transparency or alignment with the objectives of the EU Green Deal.  Positive aspects: • Undue cost or effort: The introduction of this principle, together with data quality reliefs, is strongly welcomed. It is especially critical for first-time reporters and offers pragmatic flexibility to address initial data gaps. • Value chain metrics: Allowing the use of estimates as well as direct data is a practical measure that reduces reporting burdens while maintaining relevance. • Scope reliefs: Exclusion of non-significant IRO activities and joint operations improves both feasibility and focus. • Resilience and financial effects disclosures: Limiting these to announced plans and qualitative information avoids speculative reporting and concentrates efforts on meaningful content. • Overall balance: The amendments are seen as a key simplification that will significantly reduce the reporting burden without undermining transparency.  Remaining concerns: • Interpretation issues: The definition of what constitutes \"reasonable\" effort may lead to differing interpretations and potential disagreements with auditors. Clearer guidance would be beneficial. • Supply chain reporting: Further simplification is necessary. Companies should report on their own targets, actions, policies, and metrics. Supply chain data should only be required insofar as it directly relates to the company's own commitments (e.g. sustainable procurement). Companies should not be obliged to collect detailed data from suppliers or customers. • Subsidiary thresholds: Relief measures should also apply to smaller subsidiaries (e.g. under 50 or 20 employees), which face similar challenges as SMEs in gathering sustainability data."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between flexibility for preparers and preserving transparency. Additional clarification on the interpretation of \"reasonable\" effort would help ensure consistent and practical application across companies and sectors.  Positive aspects: • Pragmatic reporting: The relief allows companies to report despite data limitations, which is especially valuable in complex value chains. • Continuous improvement: Requiring disclosure of actions to improve data quality ensures accountability and gradual enhancement over time. • No fixed time limit: Not setting a rigid deadline is reasonable, as data availability and maturity differ widely across sectors and supply chains. The requirement to disclose improvement measures already creates implicit pressure to strengthen data quality. • Alignment: The approach supports consistency with IFRS S1/S2 and significantly reduces the implementation burden without undermining credibility. • Undue cost or effort: The principle provides important flexibility for dealing with initial data gaps and enables gradual database expansion without disproportionate costs.  Remaining concerns: • Interpretation risks: There is still potential for disagreement with auditors on what constitutes a \"reasonable\" effort to improve data quality. Clearer guidance could reduce uncertainty and ensure consistent application. • Realistic expectations: ESG data, particularly from extended value chains, will never reach the same level of precision as financial data. Standards should recognize these inherent limitations to avoid undue burden."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Remove the obligation to report on financial anticipated effects, since these disclosures are neither feasible nor reliable in reflecting a company's financial situation.  If retained, we support Option 2: • Feasibility & proportionality: A qualitative-only requirement keeps reporting practical, especially for companies with limited methodologies or resources. • Avoids undue burden: Quantitative disclosures of long-term financial effects would often be speculative, uncertain, and resource-intensive, especially for family-owned or privately held companies. • Transparency with flexibility: Option 2 preserves flexibility by allowing companies to voluntarily provide quantitative information where available and relevant, without creating a mandatory obligation. • Focus on clarity: Encourages companies to provide clear narratives of expected financial implications instead of uncertain projections, which may not be comparable across firms. • Alignment with practice: Mid- and long-term financial effects are rarely available in reliable, comparable form; focusing on qualitative assessment supplemented by quantitative information only where meaningful is the more pragmatic approach. • Comparability: Quantitative projections would be highly subjective and could reduce comparability rather than improve it.  Critical observations: • Some members noted that the discussion reflects broader uncertainty about the purpose of these disclosures. In their view, financial reporting in annual reports already provides sufficient quantitative information, and sustainability reporting should not duplicate speculative forecasts. • Also with option 2 we see no necessity to disclose this information for family businesses. • While Option 2 is preferred, a few stakeholders argue that complete deletion of the requirement would also be acceptable, as this information has limited relevance for many non-listed companies. • Also with option 2 the underlying data is often unclear, and the risks cannot be reliably isolated, making any form of disclosure—whether narrative or numeric—legally risky and prone to misinterpretation. Such information lacks comparability and does not offer decision-useful insights for stakeholders."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Discrepancies between European Union accounting standards and international accounting standards result in significant costs for internationally active companies and lead to a lack of comparable information for capital markets. Companies should be allowed to use the ISSB standards as a starting point and supplement them with specific disclosures on impacts in order to achieve compliance with the CSRD/ESRS.  Although the proposals contain some positive aspects for further efficiency gains (e.g. the proposals on industry-specific disclosures), there are some proposals that pose a significant risk to interoperability (e.g. with regard to expected financial impacts). Especially new differences between the ISSB Standards and ESRS Exposure Drafts must be prevented.   Positive aspects: • Interoperability with IFRS S1/S2: Alignment of materiality and fair presentation principles with ISSB standards is a strong step toward global comparability. • Consolidation boundary: Adopting the financial consolidation boundary while allowing optional disclosure on an operational control basis reflects the logic of both the GHG Protocol and IFRS, improving consistency. • Reliefs and flexibility: Incorporation of IFRS-style reliefs, particularly the \"undue cost or effort\" clause, balances alignment with practicality for preparers. • Sector guidance: Reference to IFRS/SASB guidance as an optional source for sector-specific information is useful without creating prescriptive requirements. • Simplification maintained: ESRS-specific simplifications, such as shorter standards and removal of duplications, are preserved without undermining international alignment.  Remaining concerns: • Clarity of \"undue cost or effort\": While welcomed in principle, this concept remains vague and risks disagreements with auditors. Clearer definitions or guidance are needed to avoid inconsistent application and potential disputes. • Stability of the standards should therefore be prioritized. • Comparability risks: Without clear boundaries for reliefs, comparability of financial reporting elements within CSRD reports may be weakened."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We welcome the proposed reduction in \"shall disclose\" datapoints under materiality, as it represents a meaningful simplification and reduces the reporting burden, while maintaining the core information needed to fulfil the EU Green Deal objectives. But there is a lot of more potential to delete datapoints which are either not needed by financial users or not possible to collect for the companies. Also reducing the length of the sustainability report is very important, not just the number of data points removed, as there are significant differences in the complexity of the data points. Unfortunately, we do not expect a significantly reduced reporting volume under the amended ESRS. While the number of datapoints has decreased, the underlying disclosure obligations remain intact.   Positive aspects: • The 57% reduction in mandatory datapoints significantly lowers complexity and is particularly valuable for companies with limited resources or less ambitious reporting scopes. • Removal of less critical narrative PAT disclosures streamlines reporting and improves clarity. • Prioritization of quantitative over narrative information strengthens comparability and efficiency. • The core content of the reporting requirements has been retained, and the summary presentation makes the standards easier to understand and apply in practice.  Remaining concerns: • Environmental datapoints: While simplifications were introduced for certain areas (e.g. financial effects, own workforce), the environmental datapoints have only been partially streamlined. Some \"deleted\" requirements were merely merged or shifted, and new requirements were added. • Substances of Concern (SoCs): We strongly question the effectiveness of including SoCs in ESRS. These substances overlap with existing categories such as SVHC, leading to double counting and incomparable data.  --> Focus on the most burdensome metrics and disclosures which represent the biggest efforts. While the reduction in quantitative disclosure points represents progress, quantitative disclosures have been reduced by just 35%, leaving room for further reductions."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","The purpose of the simplification mandate is to reduce the number of data points to reduce the length of the report and to finally strengthen the meaningfulness of the report (and definitely not to increase the number of mandatory data points. Therefore, this is a step in the wrong direction. We therefore recommend to stick to the rule of no additional reporting obligations. • We particularly disagree with the disclosure of nature of corruption and bribery incidents since this information can be sensitive. We thus invoke ESRS 1 7.8 number 98: \"The undertaking is not required to disclose classified information or sensitive information even if such information is considered material.\" • ESRS E3: It should be made explicitly clear that these metrics are only to be reported if the corresponding sub-topics (\"water discharges\" and \"water withdrawal\") have been assessed as material as part of the DMA. Otherwise, these requirements could entail effort without creating added value for the reader. • ESRS E4: In any case, it should be maintained that reporting on the transition plan is only required once the transition plan has been implemented and published. The introduction of such a transition plan should remain voluntary. • ESRS G1 10 (c): In our view, this data point does not necessarily create significant added value, as the focus on the procurement team does not necessarily appear relevant. How responsibilities are assigned within the company can be individual. Therefore, the focus should continue to be on the important key positions in terms of compliance training. • ESRS G1 14: The metrics relating to anti-corruption and anti-bribery are comprehensible and ok. However, it should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","In general, we do not support the introduction of new data points, as they typically result in significant additional effort for reporting entities without a corresponding increase in decision-useful information. The cost-benefit ratio of expanding disclosure requirements must be carefully considered, and in our view, the current framework already places substantial demands on preparers.  Positive aspects: • Relevance of new datapoints: The additional datapoints are useful as they address critical issues of sustainability, always under the condition that materiality applies (except for ESRS 2 General Disclosures – BP 1, which is always mandatory). • Critical raw materials (E5-4): Treatment of critical raw materials as a separate disclosure is reasonable if – and only if – they are assessed as material. This preserves proportionality. • Waste reporting (E5-5): The newly added \"destination unknown\" category is welcome as a pragmatic exception. Where companies are able to define all waste destinations, this datapoint will simply be \"0,\" which is both feasible and transparent. Remaining concerns: • Data availability challenges: Obtaining reliable data on microplastics and critical raw materials remains very difficult for companies at the end of the value chain. Without clearer guidance, the exception may not provide sufficient relief in practice. • Waste reporting clarity: It is unclear how \"destination unknown\" differs in practice from \"waste directed to disposal\" under paragraph 18(d). Further clarification is needed to avoid inconsistent reporting."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","The goal of fair presentation should be to ensure that only information deemed material is reported. In our view, the key criterion for both fair presentation and materiality assessment should be the usefulness of the information for the intended users of the report. This clarification helps reinforce the intended purpose of the standards: to support relevant, decision-useful sustainability reporting rather than checklist-driven compliance. By emphasizing fair presentation, the ESRS framework encourages preparers to exercise professional judgment and focus on disclosures that genuinely contribute to transparency and accountability to reduce unnecessary reporting and documentation efforts, particularly when justifying the omission of non-material datapoints.  The concept of fair presentation requires clearer definitions and practical guidance to avoid disputes, ensure consistent application, and safeguard auditability. Without these clarifications, the risk remains that simplification could lead to inconsistent reporting rather than improved relevance.  Positive aspects: • The simplification and stronger risk-based approach are welcome and will reduce reporting burden by focusing on genuinely material topics. • Internal costs and efforts can be reduced, while the amendments provide clearer guidance for companies subject to ESRS. • The principle of fair presentation is positive in theory and helps avoid excessive reported information.  Concerns and limitations: • Financial adequacy: Without clearer definitions, there is a risk of oversimplified or even misleading reporting, as well as disputes with auditors. • Auditor diligence: Applying fair presentation consistently will be challenging, and it may become more difficult for auditors to demonstrate due diligence. • Interpretation risks: Non-finance employees are often less familiar with this principle, which could lead to uncertainty and inconsistent application. • Added value: In practice, the principle may not provide significant additional benefit, as disclosures are already strongly determined by the outcomes of the materiality analysis itself."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","Our members recognize both advantages and drawbacks of the proposed change to the threshold for country-by-country disclosure. Overall, the revised threshold is a pragmatic step that can improve clarity and comparability, but it may increase effort for certain companies. Clearer guidance on definitions (especially regarding ESRS S1-6) is necessary to ensure consistent application and to avoid undermining the simplification objective.  Positive aspects: • The new approach of reporting for the top 10 largest countries (with >50 employees) is more practical and easier to handle for many companies. • Using a percentage-based approach supplemented with a breakdown of the top 10 countries provides meaningful detail without requiring a disproportionate reporting effort. • Much of this information is usually available in existing HR systems, so for many companies the change will not create additional data collection challenges.  Concerns and limitations: • For some companies, the new threshold will in fact require disclosure for a larger number of branches than before. This may increase workload and run counter to the simplification objective. • It remains unclear how to deal with ESRS S1-6 (\"significant driver\") and how to define significance transparently. The criteria for excluding or including datapoints on non-employee characteristics lack clarity and risk inconsistent application."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","We see the proposed changes as a step forward but highlight important areas where clarification is still required to ensure consistent application. While the proposed methodology is a reasonable starting point, clearer definitions, prioritization of data sources, and explicit guidance on subnational agreements and EU benchmarks are essential. This will ensure that reporting on adequate wages is both feasible for preparers and reliable for users.   Positive aspects: • Referencing the EU Directive on Adequate Minimum Wages would provide a clear benchmark for calculations within the EU. • Establishing a hierarchy of sources for non-EU adequate wages would improve consistency. For example, widely recognized global databases such as the Global Living Wage Coalition or WageIndicator should be prioritized before relying on generic estimates.  Concerns and remaining questions: • It remains unclear how to deal with subnational agreements outside the EU. Clearer examples or guidance are needed to ensure companies can apply the methodology consistently. • More detailed information is required on which benchmarks should be used for calculating adequate wages within the EU, especially in cases where national or sectoral agreements differ. • Without such clarifications, the comparability of wage disclosures across companies and regions will remain limited."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","If the disclosure specifications and application requirements for E4-4 (targets) have largely been removed from the application requirements for companies when setting biodiversity and ecosystem targets as part of the simplification process, then it is imperative that clear guidance be provided elsewhere. If ESRS Set 1, E4 AR 26 is truly outdated, then it urgently needs to be revised.  This would empower companies to set targets that are relevant to their specific material impacts, if any exist, rather than forcing compliance with a one-size-fits-all standard.  Primary goal must be simplification and reinforcing the materiality principle, not adding more complex target-setting rules. We identified two key risks with overly prescriptive guidance. First, biodiversity metrics are still methodologically immature. Unlike climate, there is no single, globally accepted framework. Mandating a specific approach, such as SBTN, would be premature and could lock companies into methodologies that may become outdated or are dictated by a single organization. We argue that flexible target setting options are essential. Second, detailed guidance undermines the Double Materiality Assessment (DMA) by creating a \"checklist\" effect. This pressures companies to report on a topic even if their own assessment deems it non-material."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","We do not have a single perspective on the deletion of the voluntary datapoint on the adjusted gender pay gap. Overall, while some simplification is achieved by deleting the voluntary adjusted datapoint, this comes at the expense of comparability and meaningful interpretation.   Concerns about deletion: • An adjusted gender pay gap provides more meaningful and fair insights, as it takes into account the function, role, or qualification of employees. Without such adjustment, unadjusted figures may promote misleading conclusions or reinforce structural discrimination. • Deleting the voluntary adjusted datapoint risks reducing comparability and nuance, especially in industries with specific role- or qualification-based differences.  Arguments for deletion: • Reporting only the unadjusted pay gap is consistent with other EU directives and avoids creating parallel or conflicting reporting obligations. • While the unadjusted figure can be open to misinterpretation, aligning with existing legislation ensures coherence and limits additional reporting burdens."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","We acknowledge that the revised formulation continues to provide some level of transparency on payment practices, but important concerns remain regarding the protection of SMEs.  Positive aspects: • Even without clause 33(a), companies are still required to disclose standard payment terms and the percentage of invoices aligned with these terms. This ensures a degree of visibility on payment practices that affect SMEs. • This disclosure helps identify whether companies have consistent policies in place regarding payment periods. • It did not offer meaningful insights and was difficult to interpret in a decision-useful way.   Concerns: • The omission of clause 33(a) is problematic, as it removes explicit transparency on how long suppliers actually wait to be paid. SMEs, in particular, are vulnerable to late payments and often lack the bargaining power to enforce fair practices. • The deleted requirement would have provided a more detailed and concrete picture of payment behavior by disclosing the average payment time. Its absence risks weakening protections for SMEs. • While average payment time is influenced by company-specific cycles (e.g. weekly or bi-weekly runs), it nevertheless offers valuable information on whether small suppliers face structural disadvantages. • We also question the relevance and practicality of the remaining datapoint on \"standard payment terms\". • Also disclosures on standard payment terms are already partially covered by existing financial reporting requirements, in particular IAS 7.44.  • Furthermore, the categorization of suppliers (e.g., SMEs) remains problematic."]
["Survey","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"On page 27 of Annex II, under 'Recovery', energy recovery and biological circular waste that is not returned to the cycle (i.e. mainly fermentation) are expressly excluded from the definition of \"recovery\" and would therefore be classified as 'disposal'.   This contradicts the waste hierarchy within the meaning of the Waste Framework Directive (WFD), according to which energy recovery is explicitly defined as 'recovery'. Recovery should be based on the WFD definition and therefore also include energy recovery: if the R1 criterion for energy efficiency is met. Composting and fermentation are recycling within the meaning of Article 3(17) of the WFD, provided that a nutrient cycle is created. Fermentation for energy recovery is also recovery according to Article 3(5) of the WFD."]
["Survey","AFNOR","Standard setting initiative","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","We acknowledge that the proposed amendments to Chapter 3 of ESRS 1 simplify the DMA process and reinforce the information materiality filter, reducing the risk of a checklist approach. The option for both top-down and bottom-up workflows, and the greater emphasis on outcome-focused disclosures, are welcome steps toward proportionality and usability.  However, while the drafting is clearer, the amendments do not yet fully strike an acceptable balance between simplification and robustness because the DMA remains detached from recognised, consensus-based international standards. ESRS requirements should be anchored in harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or equivalent ISO management systems (e.g., ISO 14001, 26000, 50001). These are built through a robust, democratic process that ensures legitimacy, protects the relevance of the EU standardisation system, and enables international scalability. In contrast, ESRS \"common specification\"-type provisions risk weakening the established standardisation framework and isolating Europe from the global playing field.  By formally recognising such standards in the DMA process, ESRS would:  Reduce the burden on companies, especially SMEs, by allowing re-use of existing evidence from certified management systems;  Increase trust and acceptance among preparers, auditors, and users through the legitimacy of established norms;  Demonstrate value to national stakeholders, showing that National Standards Bodies (NSB) and Committees (NC) are proactive in supporting the implementation of EU policy.  We also recommend including practical tools such as a short decision tree, minimum documentation templates, and clear guidance on aggregation/disaggregation, to maintain robustness while further improving usability."]
["Survey","AFNOR","Standard setting initiative","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","The updated guidance in Paragraphs 34–36 and Appendix C is a welcome step toward clarifying how implemented remediation, mitigation, and prevention measures should influence the double materiality assessment. The emphasis on differentiating gross from net impacts and recognising the effect of preventive actions supports more targeted and meaningful disclosures.  That said, the methodology would benefit from a stronger foundation in formal, consensus-based standards — notably harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or relevant ISO management systems (e.g., ISO 14001, ISO 26000, ISO 50001). These frameworks offer tried-and-tested approaches for evaluating residual risks and improvements after action is taken, developed through a transparent and internationally recognised process.  Without this connection, ESRS risk evolving into stand-alone \"common specifications\" with limited legitimacy and weaker global interoperability. By embedding recognised standards into the DMA approach, EFRAG could:  Safeguard the authority of the EU standardisation system and avoid undermining its established processes;  Ease compliance for companies, particularly SMEs, through reuse of data, controls, and audits already performed under certified systems;  Reinforce the role of National Standards Bodies and Committees as active partners in implementing EU sustainability policy.  We further suggest allowing preparers to focus disclosures on the residual severity and likelihood of impacts once robust, standardised systems are in place, supported by proportionate evidence requirements. This would make reports both more comparable and less burdensome, while maintaining alignment with global practices."]
["Survey","AFNOR","Standard setting initiative","France","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We support the proposed amendments under Lever 2 as they enhance flexibility, promote conciseness, and strengthen the integration of sustainability statements with overall corporate reporting. Allowing an executive summary, encouraging the use of appendices for detailed data, and clarifying \"connected information\" will make sustainability disclosures more accessible to a broader audience and reduce unnecessary duplication.  To maximise the benefits, these improvements should be complemented by explicit recognition of harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO. Referencing recognised, consensus-based standards for methodologies and terminology would:      Protect the relevance of the EU standardisation system, avoiding parallel, non-standardised frameworks;      Reduce the burden on preparers, particularly SMEs, by enabling them to reuse content from certified management systems (e.g., ISO 14001, ISO 26000, ISO 50001) in both narrative and data sections;      Demonstrate to national stakeholders that National Standards Bodies and Committees are actively supporting CSRD implementation.  We also encourage EFRAG to publish a cross-reference matrix between the sustainability statement structure and topical ESRS disclosure requirements, as well as with related financial reporting references. This would further improve connectivity, reduce fragmentation, and facilitate assurance processes.  By embedding these readability measures in a framework aligned with robust, internationally recognised standards, the ESRS will remain both user-friendly and globally interoperable, ensuring that simplification does not come at the cost of legitimacy or comparability."]
["Survey","AFNOR","Standard setting initiative","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We welcome the restructuring of ESRS 2 and its improved interaction with topical standards. The streamlined \"General Disclosure Requirements\" and the more principles-based approach to policies, actions, and targets (PAT) enhance clarity and usability while maintaining the ability to deliver relevant and comparable information. Removing duplicative topical specifications and strengthening the link between PAT and IROs will reduce preparation effort without undermining robustness.  To ensure that this simplification is durable and internationally scalable, ESRS should explicitly align with recognised, consensus-based international standards — for example, harmonised European standards (hENs) under the Vienna Agreement between CEN and ISO, as well as specific ISO and IEC management system and reporting frameworks such as ISO 9001 (quality management), ISO 14064 (GHG quantification), ISO 45001 (occupational health & safety), and ISO 37001 (anti-bribery). These standards are developed through rigorous, transparent processes and already provide tested structures for setting policies, defining actions, monitoring targets, and ensuring continual improvement.  Integrating such references would:  Protect the authority of the EU's standardisation system and avoid creating parallel, less legitimate \"common specifications\";      Reduce burden, especially for SMEs, by enabling reuse of documentation, controls, and KPIs already maintained under certified systems;  Showcase to national stakeholders that National Standards Bodies and Committees are proactively enabling CSRD implementation.  We recommend complementing the architectural simplification with a reference mapping tool that connects ESRS 2 requirements to equivalent clauses in recognised European and international standards. This would allow preparers to directly link sustainability reporting to their existing compliance and management frameworks, improving both efficiency and auditability.  By pairing the structural clarity of Lever 3 with explicit ties to robust global standards, the ESRS will achieve genuine simplification without losing relevance, comparability, or international alignment."]
["Survey","AFNOR","Standard setting initiative","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","While the removal of \"may disclose\" provisions and the relocation of mandatory application requirements directly beneath their corresponding disclosure requirements are steps toward a cleaner structure, these amendments alone do not fully achieve the desired level of clarity and accessibility. The language is more concise, but without explicit reference to recognised, consensus-based standards — such as harmonised European standards (hENs) under the Vienna Agreement between CEN and ISO, or relevant ISO and IEC frameworks (e.g., ISO 14064, ISO 50001, ISO 45001, ISO 37000) — the ESRS risk remaining self-contained \"common specifications\" with limited legitimacy and weaker international interoperability.  The current drafting still leaves room for interpretation that could lead to inconsistent application across sectors and jurisdictions. For SMEs in particular, the absence of clear pathways to reuse existing data, processes, and audit trails from certified management systems may actually increase preparation effort despite the intention to simplify.  To deliver genuine clarity and accessibility, the mandatory content should:  Reference established standards for definitions, methodologies, and calculation rules, protecting the authority of the EU standardisation system;  Incorporate a mapping tool linking ESRS requirements to equivalent provisions in CEN–ISO norms to guide preparers toward existing, verifiable sources of evidence;  Explicitly recognise certified management systems as acceptable means of meeting certain disclosure requirements, reducing duplication.  Without these linkages, the ESRS risk creating a parallel framework that isolates Europe from global reporting practice and misses an opportunity to demonstrate to national stakeholders that NSBs and NCs are proactively enabling EU policy implementation through proven, internationally recognised tools."]
["Survey","AFNOR","Standard setting initiative","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","The intention behind the NMIG — to provide optional, illustrative guidance and remove it from the Delegated Act — is understandable. However, in practice, its ambiguous status risks creating grey areas that undermine both simplification and legal certainty. Even if officially \"non-mandatory,\" preparers, auditors, and regulators may treat NMIG content as a de facto checklist, especially where it reproduces elements formerly embedded in mandatory datapoints. This could reintroduce compliance pressure and increase workload, particularly for SMEs, contrary to the stated goal of datapoint reduction.  If guidance is necessary, it should be firmly anchored in recognised, consensus-based international standards — such as harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, and relevant ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 50001 for energy management, ISO 26000 for social responsibility, ISO 37000 for governance). These established references provide clear, legitimate methodologies without creating an \"ESRS-only\" layer of pseudo-obligations.  To avoid confusion and burden creep:  NMIG should be formally separated from compliance assessments, with explicit safeguards preventing its use as an implicit requirement;  Where possible, NMIG examples should be replaced or supplemented with references to existing CEN–ISO norms, allowing preparers to leverage certified management systems and avoid duplicate reporting structures;  EFRAG and the Commission should make clear that auditors cannot request justification for non-use of NMIG elements.  Without these safeguards, NMIG risks functioning as unofficial mandatory guidance — eroding the credibility of the simplification process, weakening the role of formal standardisation, and isolating the EU framework from globally recognised approaches."]
["Survey","AFNOR","Standard setting initiative","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","The additional reliefs — including \"undue cost or effort,\" partial scope with improvement plans, and flexibility between direct data and estimates — are welcome in principle and respond to repeated stakeholder concerns about the reporting burden. These measures, if applied proportionately, can help align ESRS with the practical realities faced by preparers, especially SMEs.  However, the amendments still fall short of providing a fully effective and coherent burden relief framework. The reliefs remain self-contained within the ESRS and are not sufficiently anchored in recognised, consensus-based standards such as harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or relevant ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 50001 for energy management, ISO 45001 for occupational health and safety). These established standards already include tested mechanisms for scoping, data quality management, and materiality thresholds — mechanisms that could be directly referenced to reduce complexity and improve interoperability.  Without this grounding, the reliefs risk being applied inconsistently, creating uncertainty for both preparers and auditors. In addition, the lack of explicit recognition of certified management systems as valid evidence of due process and continual improvement undermines the potential efficiency gains: companies may still face duplicative processes rather than leveraging existing compliance infrastructures.  To better balance burden reduction with transparency and interoperability:      Link ESRS relief conditions to the existence of recognised management systems, allowing reliance on ISO-certified processes as a \"safe harbour\";      Publish a clear mapping to equivalent IFRS S1/S2 relief provisions and to relevant CEN–ISO clauses;      Ensure reliefs are accompanied by proportional documentation requirements to maintain trust without imposing hidden burdens.  Only by integrating these reliefs with established standards can the ESRS truly deliver simplification while safeguarding transparency and legitimacy in the context of the EU Green Deal."]
["Survey","AFNOR","Standard setting initiative","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","Providing flexibility to report metrics with a partial scope when no reliable direct or estimated data are available is a pragmatic step that recognises current data limitations, particularly in extended value chains. The requirement to disclose actions to improve coverage is also positive.  However, the absence of any time limit on the use of this relief risks turning it into a permanent exemption rather than a temporary bridge toward full data coverage. This could undermine comparability and dilute incentives for systematic improvement. Without clear guardrails, the relief could also be applied inconsistently across sectors and jurisdictions.  To ensure both flexibility and accountability, this provision should be explicitly linked to recognised, consensus-based standards for data quality management and continual improvement — for example, harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or ISO/IEC frameworks such as ISO 14064 (GHG accounting), ISO 50001 (energy management), and ISO 9001 (quality management). These standards already provide well-defined processes for establishing baselines, improving data coverage, and auditing progress.  We recommend:      Setting a clear time limit or review period for the use of the relief, with the possibility of justified extensions;      Allowing undertakings to rely on certified management systems as evidence of credible improvement plans, creating a \"safe harbour\" for compliance;      Publishing a mapping between ESRS paragraph 92 and equivalent IFRS S1/S2 provisions, as well as relevant clauses in CEN–ISO standards, to strengthen interoperability and legal certainty.  By grounding the relief in established international standards and ensuring it remains temporary and measurable, EFRAG can provide real flexibility for preparers without creating a loophole that weakens the quality and completeness of reported information."]
["Survey","AFNOR","Standard setting initiative","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","Neither Option 1 nor Option 2 provides a satisfactory balance between transparency for users and practicability for preparers. Option 1 maintains a quantitative requirement but without sufficiently clear methodological anchors, which risks inconsistent application and high compliance costs without guaranteeing comparability. Option 2 removes the quantitative requirement altogether, which would result in a significant loss of decision-useful information for investors and reduce incentives for companies to improve their methodologies.  A more effective approach would explicitly anchor any relief or requirement in recognised, consensus-based international standards — for example, harmonised European standards (hENs) under the Vienna Agreement between CEN and ISO, and relevant ISO frameworks such as ISO 14064 (GHG accounting), ISO 14008 (monetary valuation of environmental impacts), ISO 50001 (energy management), and ISO 31000 (risk management). These standards already provide robust methodologies for estimation, scenario analysis, uncertainty quantification, and valuation, which could serve as a \"safe harbour\" for ESRS compliance.  In practice, this would mean:      Retaining quantitative disclosure where feasible, but allowing omission only if the entity demonstrates the absence of reasonable and supportable data as defined in established standards;      Requiring disclosure of the basis of estimation and uncertainty ranges, linked to recognised methodologies;      Providing a crosswalk to IFRS S1/S2 relief provisions to ensure global interoperability.  Without such alignment, Option 1 risks being burdensome without delivering consistent value, while Option 2 risks undermining the credibility and ambition of the ESRS framework. Both would leave Europe with a fragmented approach, disconnected from the international standardisation ecosystem and from the legitimate, consensus-driven processes that underpin durable and scalable reporting practices."]
["Survey","AFNOR","Standard setting initiative","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","Retaining datapoints essential for assessing transition and physical risk is justified, but the absence of explicit reference to recognised, consensus-based standards leaves preparers without a clear technical anchor. Aligning these requirements with harmonised European standards (hENs) under the Vienna Agreement between CEN and ISO, and relevant ISO methodologies — such as ISO 14064 (GHG accounting), ISO 14090 (climate adaptation), ISO 14091 (climate risk assessment), and ISO 14008 (monetary valuation of environmental impacts) — would:      Provide robust and internationally recognised approaches for scenario modelling, valuation, and uncertainty management;      Reduce duplication by allowing reuse of outputs from certified management systems and regulatory climate-risk assessments;      Strengthen global interoperability, benefiting both EU and non-EU stakeholders.  We recommend:      Embedding these standard references directly into the application requirements to create a \"safe harbour\" for compliance;      Allowing range-based or scenario-based reporting where exact quantification is not feasible, provided the method is consistent with recognised standards;      Publishing a mapping between DR E1-11 datapoints and equivalent IFRS S2 and sector-specific frameworks (e.g., NGFS scenarios, TCFD guidance) to facilitate alignment.  Without such methodological integration, the amended provisions risk continuing to impose high effort for uncertain comparability, missing the opportunity to ground ESRS climate financial effect disclosures in legitimate, consensus-driven standards that enable both simplification and international scalability."]
["Survey","AFNOR","Standard setting initiative","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We acknowledge EFRAG's efforts to improve interoperability with IFRS S1 and S2, such as aligning the GHG boundary with the financial consolidation approach and harmonising terminology. These changes make it easier for dual reporters to navigate both frameworks.  However, the current approach remains focused on alignment with ISSB standards alone and does not sufficiently integrate recognised, consensus-based technical standards from the European and international standardisation system — for example, harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or ISO/IEC methodologies like ISO 14064 (GHG accounting), ISO 14090/14091 (climate adaptation and risk assessment), and ISO 50001 (energy management). Anchoring interoperability in these robust, global standards would:      Reduce duplication with other reporting regimes, an issue already flagged by multiple stakeholders;      Allow companies — especially those already subject to sectoral or regulatory reporting — to reuse existing processes and data, cutting administrative workload;      Strengthen the legitimacy of ESRS by connecting them to the broader standardisation ecosystem rather than creating a parallel \"ESRS-only\" layer.  Interoperability should also prevent the cascade effect down value chains, where CSRD/CS3D obligations are passed de facto to suppliers via direct data requests or mandatory platforms. Without safeguards, such knock-on effects could undermine the simplification objectives and disproportionately affect SMEs.  To achieve a truly balanced outcome, we recommend:      Publishing a triangular mapping between ESRS, IFRS S1/S2, and relevant CEN–ISO standards;      Ensuring that reliefs beyond IFRS do not create new gaps or inconsistencies;      Embedding a progressive approach and group-level reporting options to ease the transition without sacrificing transparency.  This broader, standards-based interoperability would better serve both EU policy goals and the operational realities of preparers."]
["Survey","AFNOR","Standard setting initiative","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I disagree"]
["Survey","AFNOR","Standard setting initiative","France","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","We acknowledge that moving six datapoints from \"may\" to \"shall\" represents a very limited change compared to the overall datapoint reduction, and that these items are linked to existing disclosure objectives rather than introducing new concepts. Making these elements explicit can indeed improve clarity for both preparers and users.  However, even small increases in mandatory reporting should be carefully assessed against the structural objective of reducing complexity and duplication. Without anchoring these additional \"shall\" datapoints in recognised, consensus-based technical references — such as ISO/CEN standards —  there is a risk of reintroducing fragmented requirements.  If these datapoints are not cross-referenced to established methodologies, companies may still need to perform bespoke analyses to satisfy ESRS, even where equivalent data or processes already exist under other frameworks (e.g., SFDR, EU Taxonomy, CS3D, sector-specific standards). This undermines the stated goal of simplification and increases the likelihood of cascade effects in value chains, particularly affecting SMEs.  To mitigate this, we recommend:  Publishing a mapping between the six datapoints and equivalent clauses in IFRS S1/S2 and relevant CEN–ISO standards;      Allowing preparers to rely on outputs from certified management systems to meet these requirements;  Monitoring implementation to ensure these additions do not become a precedent for gradually re-expanding the datapoint set.  Even a small shift from voluntary to mandatory status should be accompanied by strong interoperability measures, to maintain both the credibility of the simplification process and the legitimacy of the ESRS within the wider standardisation ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree"]
["Survey","AFNOR","Standard setting initiative","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","Clarifying that ESRS is a \"fair presentation\" framework — in line with IFRS S1 and S2 — has the potential to move reporting away from a purely compliance-driven, checklist approach. In theory, this could allow the materiality filter to operate more effectively and reduce the volume of immaterial information disclosed.  However, in practice, the fair presentation requirement may also introduce greater subjectivity and uncertainty, especially in areas like impact materiality where established methodologies and benchmarks are less mature. This could lead to inconsistent interpretations, heightened legal exposure, and increased audit costs, particularly for smaller preparers.  We would recommend:  Publishing clear examples and sector-based benchmarks, linked to established standards, to guide preparers' judgements;  Allowing reliance on certified management systems as evidence of an adequate process for determining material disclosures;  Ensuring alignment with other EU regulatory definitions to avoid conflicting interpretations of materiality.  Without these safeguards, there is a risk that the fair presentation approach — while conceptually sound — could inadvertently increase complexity and liability rather than reduce it."]
["Survey","AFNOR","Standard setting initiative","France","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","The disclosure of both GHG emissions intensity targets and associated absolute values can, in principle, provide a more complete picture of an undertaking's climate progress. While intensity metrics reflect efficiency gains, they can mask increases in overall emissions; absolute figures address this but ignore the effects of business growth. Having both is generally valuable for transparency.  That said, for financial institutions, estimating absolute emissions linked to portfolio targets involves highly uncertain modelling and a large number of forward-looking assumptions (portfolio composition, sectoral shifts, production capacity, market shares, intensity trajectories). Without robust, standardised methodologies, such disclosures risk being unreliable and of limited decision-usefulness, while significantly increasing the reporting burden.  To address this, ESRS should explicitly reference recognised, consensus-based methodologies — such as those embedded in harmonised European standards (hENs) under the Vienna Agreement between CEN and ISO, and sector-specific frameworks like ISO 14097 (climate finance and investment), the Partnership for Carbon Accounting Financials (PCAF) Standard, and relevant ISO 14064 provisions. These could serve as a \"safe harbour\" for calculating and disclosing absolute values, ensuring methodological consistency and comparability.  We recommend:      Allowing financial institutions to disclose absolute targets only where they can be derived from established, verifiable methodologies;      Providing clear guidance and worked examples for the sector, aligned with ISO/CEN standards, to limit variability;      Ensuring that any sector-specific relief maintains a level playing field by being based on objective feasibility criteria rather than sector exemptions alone.  Without such methodological anchors and proportionality safeguards, this requirement risks generating opaque or misleading figures, adding complexity without materially improving the quality of climate disclosures."]
["Survey","AFNOR","Standard setting initiative","France","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","Changing the disaggregation threshold from a proportional measure (≥50 employees representing at least 10% of the workforce) to a \"top 10 largest countries\" rule can improve comparability and ensure that disclosures capture a broader set of geographies. It also simplifies the trigger condition, which may be easier to apply in practice.  However, for multinational groups with a wide geographic footprint, this approach could increase the number of countries to be reported, particularly in cases where operations are spread across many small or medium-sized jurisdictions. Even if the raw data is \"usually accessible,\" additional segmentation, quality checks, and reconciliation for each country can create a meaningful administrative burden — especially for entities with decentralised HR systems or partially outsourced functions.  To balance transparency and proportionality, we recommend:      Allowing undertakings to aggregate smaller jurisdictions into a residual \"other countries\" category once the threshold of 80–90% total employee coverage is reached;      Recognising the use of established HR and workforce reporting standards (e.g., ISO 30414 on human capital reporting) and certified HR information systems as a \"safe harbour\" for data accuracy and scope;      Embedding a progressive approach for first-time reporters, especially SMEs or subsidiaries, to avoid disproportionate initial compliance costs;      Providing explicit alignment with related EU frameworks (e.g., equal pay reporting under EU law) to prevent duplication of disclosures.  Without these safeguards, the shift to a top-10-country requirement risks eroding some of the simplification gains by increasing country-level granularity beyond what is decision-useful for many stakeholders, while adding workload that could be avoided through proportional aggregation and reliance on recognised standards."]
["Survey","AFNOR","Standard setting initiative","France","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","Aligning the ESRS S1 methodology for non-EU adequate wages with the 2024 ILO Governing Body agreement is a step toward greater consistency with international labour standards. However, several aspects of the amended approach raise concerns regarding clarity, comparability, and ambition.  First, the current hierarchy risks accepting minimum wages far below an adequate wage as compliant disclosures, particularly in jurisdictions where statutory minima are not aligned with living wage benchmarks. Second, by placing the assessment of relevant living wage datasets as a \"last resort,\" the methodology may unintentionally discourage the use of the most meaningful data source for assessing wage adequacy. Third, the absence of a requirement to disclose which prong of the methodology has been applied significantly reduces comparability across undertakings and geographies.  To address these issues, we recommend:      Embedding explicit references to recognised international standards — such as ILO conventions, ISO 26000 (social responsibility), and harmonised European standards (hENs) under the Vienna Agreement — as methodological anchors;      Requiring disclosure of the methodological prong applied, along with justification, to enable comparability and assurance;      Encouraging the use of living wage benchmarks (e.g., Global Living Wage Coalition methodology) as a primary rather than last-resort option;      Aligning definitions and wage calculation principles with other EU frameworks (e.g., Equal Pay Directive) to prevent duplication and inconsistencies.  Without these refinements, the revised AR 22 risks producing wage adequacy disclosures that are technically compliant but substantively weak, potentially undermining both stakeholder trust and the EU's stated social sustainability objectives. Anchoring the methodology in robust, consensus-based standards would ensure that the simplification effort does not come at the cost of meaningful transparency or comparability."]
["Survey","AFNOR","Standard setting initiative","France","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","The current integration of SFDR PAIs into the Amended ESRS still presents three structural challenges:      Relevance filter – Investor feedback already indicates that some PAIs are of limited practical relevance. Without a robust materiality-based filter, companies may still have to produce data of marginal decision-usefulness, diluting focus and increasing cost.      Standardisation gap – Many PAI-related datapoints are not explicitly tied to recognised, consensus-based technical standards, such as harmonised European standards (hENs) under the Vienna Agreement between CEN and ISO, or ISO/IEC frameworks like ISO 14064 (GHG accounting), ISO 30414 (human capital), and ISO 26000 (social responsibility). Anchoring in these norms would improve comparability and allow reuse of existing compliance data.      Duplication risk – Even after consolidation, overlaps remain between ESRS and SFDR requirements. Without clear crosswalks and interoperability tools, preparers risk parallel data collection exercises for essentially the same indicators, increasing administrative burden — particularly for dual reporters and SMEs in value chains.  To strengthen integration while maintaining simplification, we recommend:      Publishing a mapping table between each SFDR PAI and its corresponding ESRS datapoint, along with references to relevant CEN–ISO clauses;      Embedding a proportionality principle so that low-relevance PAIs are disclosed only when material;      Recognising certified management systems and established reporting tools as \"safe harbours\" for meeting certain PAI requirements.  Without these measures, the SFDR–ESRS link risks maintaining complexity under a different form, rather than delivering the intended streamlining."]
["Survey","AFNOR","Standard setting initiative","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Providing companies with methodological guidance for biodiversity- and ecosystems-related targets is essential, particularly as target-setting in this field is still evolving and highly context-dependent. The current AR 26 offers useful examples (e.g., hectares restored, natural surfaces recreated, number of sites with approved ecological integrity), but it does not yet reflect the state of the art in biodiversity target methodologies.  To be credible and comparable, AR 26 should be updated to align with internationally recognised biodiversity frameworks such as the Science Based Targets Network (SBTN), the Global Biodiversity Framework (GBF) under the CBD, and the recommendations of the Taskforce on Nature-related Financial Disclosures (TNFD). These initiatives emphasise measurable outcomes linked to ecological integrity, species diversity, ecosystem services, and landscape connectivity — going beyond purely area-based metrics.  Additionally, guidance should be anchored in consensus-based technical standards relevant to biodiversity, for example:      ISO 14055 (land degradation neutrality) for restoration planning and monitoring;      ISO 14007/14008 for valuing biodiversity-related environmental costs and benefits;      ISO 37120+ series for ecosystem services indicators at site or community level.  These standards provide structured, verifiable methodologies that could serve as a \"safe harbour\" for ESRS compliance, reduce the risk of inconsistent approaches, and support comparability across sectors and geographies.  Without these updates, biodiversity targets may remain inconsistent, difficult to verify, and potentially misaligned with scientific priorities. This could undermine stakeholder trust and the effectiveness of the EU's contribution to global biodiversity goals.  We recommend that AR 26:      Integrate SBTN/GBF-aligned indicators;      Link to relevant CEN–ISO standards;      Provide sector-specific examples for high-impact industries (e.g., forestry, mining, agriculture, infrastructure).  This would ensure biodiversity targets are scientifically grounded, standardised, and operationally feasible."]
["Survey","AFNOR","Standard setting initiative","France","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","Maintaining the unadjusted global gender pay gap aligns with the Pay Transparency Directive (EU) 2023/970 and ensures consistency with an established EU legal requirement. However, deleting the adjusted gender pay gap by employee category removes an important datapoint that can significantly enhance the interpretability and relevance of pay equity disclosures.  The unadjusted gap provides a high-level indicator but can be heavily influenced by workforce composition, job segregation, and structural factors unrelated to equal pay for equal work. Without the adjusted metric — especially when broken down by employee category or country — stakeholders risk drawing misleading conclusions about an organisation's actual pay equity performance.  Rather than complete deletion, we recommend retaining the adjusted metric as a proportionate, materiality-based requirement and anchoring its calculation in recognised, consensus-based standards such as:      ISO 30414 (human capital reporting) for pay equity metrics;      CEN guidelines on gender equality plans (developed under the Vienna Agreement);  This would allow companies to use established methodologies, reduce the risk of inconsistent approaches, and enable comparability across sectors and jurisdictions.  We also note that maintaining the adjusted metric could help prevent cascade effects in value chains, where investors or large clients request this data outside the ESRS framework, reintroducing the burden the deletion sought to remove. By keeping it within ESRS under clear methodological guidance, preparers could control how it is calculated and communicated.  In summary, while simplification is important, deleting the adjusted gender pay gap datapoint risks weakening the quality and usefulness of social disclosures. A balanced approach would be to retain it with clear methodological anchors and a proportionality principle."]
["Survey","AFNOR","Standard setting initiative","France","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","Replacing former G1-2 and G1-6 \"payment practices\" datapoints with generic PAT disclosures improves readability, but it risks reducing visibility on concrete behaviours that affect SMEs' liquidity. Narrative PAT alone is unlikely to provide the discipline and comparability needed to meet the CSRD's SME-protection objective.  A proportionate fix would be to retain a minimal set of standardised, decision-useful KPIs, subject to materiality, while keeping PAT for context. For example:      Median/weighted-average days to pay for SME suppliers (reported separately from non-SMEs).      % of SME invoices paid beyond agreed terms (and % paid within 30/60 days).      Disputed-invoice rate and median time to resolve disputes.      Existence and uptake of early-payment/fast-track options for SMEs (e.g., dynamic discounting), and transparency on supplier finance/reverse-factoring programs and their terms.  These indicators are simple to extract from AP systems, auditable, and directly tied to SME resilience. To avoid burden creep, provide safe harbours by allowing companies to rely on processes certified or assessed against recognised, consensus-based standards (e.g., ISO 20400 on sustainable procurement, ISO 44001 on collaborative business relationships, ISO 9001 for order-to-pay controls, ISO 37000 for governance). Where such systems are in place, PAT can reference them, and the KPIs above become a concise outcome check rather than a parallel framework.  Additional safeguards to prevent unintended cascade effects down the value chain:      Permit aggregation where SME coverage ≥80–90% of supplier spend is reached.      Encourage country/segment breakdowns only where material (e.g., known late-payment hotspots).      Provide a brief assurance-ready template (definition of \"SME supplier\", inclusion/exclusion of disputed invoices, and treatment of payment-term extensions).  In short, keep PAT, but re-introduce a small, harmonised KPI core on payment timeliness and dispute handling. This preserves simplification while delivering the specific transparency needed to protect SMEs in practice."]
["Survey","AFNOR","Standard setting initiative","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","AFNOR","Standard setting initiative","France","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The simplifications achieved in the Amended ESRS are visible in reduced datapoints, improved structure, and clarified wording. These changes are welcome insofar as they address readability and some implementation issues. However, they do not sufficiently resolve structural causes of complexity, nor do they secure true interoperability with global frameworks or national standardisation systems.  The core issue is that ESRS remains non-founded on recognised, consensus-based standards. Unlike harmonised European standards (hENs) developed under the Vienna Agreement between CEN and ISO, or widely adopted ISO/IEC frameworks (e.g., ISO 14064 for GHG accounting, ISO 26000 for social responsibility, ISO 45001 for OH&S), the ESRS lacks the robust legitimacy, scalability, and international alignment such standards confer.  Without systematic alignment, undertakings risk duplication and conflicting requirements under other EU legislation (SFDR, EU Taxonomy, CS3D) or international initiatives (ISSB, SBTN, TNFD). This can reintroduce burden via parallel reporting channels, undermining the simplification goal.  We recommend:      Embedding explicit references to CEN–ISO standards as implementation \"safe harbours\";      Aligning terminology and data models with globally recognised frameworks to ensure interoperability;      Providing proportionality measures tailored for SMEs while preserving decision-useful transparency;      Clarifying the Glossary to incorporate precise definitions harmonised with technical standards.  The simplification is a step forward, but without standardisation-based anchoring, it risks being cosmetic and leaves Europe isolated from the international reporting ecosystem."]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree"]
["Survey","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany","35.E5-5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree",null,"E5","Disclosure Requirement E5-5 - Resource outflows",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.ESRS1_7.1."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS1","7.1 Presenting comparative information",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.ESRS1_7.5."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS1","7.5. Updating disclosures about events after the end of the reporting period",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.ESRS1_8."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS1","8. Presentation requirements and structure of the sustainability statement",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.ESRS1_8.1."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS1","8.1 General presentation requirement, structure and content of the sustainability statement",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.ESRS1_8.2."," Do you agree with the amendments of this chapter? ","I agree",null,"ESRS1","8.2 Presentation of additional information included in the sustainability statement",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E1-3."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-3 - Resilience in relation to climate change",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E1-5."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-5 - Actions and resources in relation to climate change",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E1-7."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-7 - Energy consumption and mix",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E1-8."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E5-1."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-1 - Policies related to resource use and circular economy",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E5-2."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-2 - Actions and resources related to resource use and circular economy",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E5-3."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-3 - Targets related to resource use and circular economy",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E5-4."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-4 - Resource Inflows",""]
["Survey","Majesty Business Utvikling","Consultant (including software vendor)","Norway","35.E5-5."," Do you agree with the amendments of this chapter? ","I agree",null,"E5","Disclosure Requirement E5-5 - Resource outflows",""]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The aggregation and streamlining of information and requirements simplifies the process. However, the DMA should not be done top-down. There are several aspects of DMA that cannot be completed top-down, such as assessing whether business locations are located near biodiversity sensitive areas, in proximity to affected communities, or within watersheds experiencing water stress. This is still a point that has not been clarified and that some companies may miss. Without clear guidance on the bottom-up approach, companies risk conducting superficial desktop assessments that fail to identify material nature-related impacts and dependencies, potentially leading to non-compliance and missed business risks."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","Comment: An Executive Summary makes it easier to understand the overall response, and potentially its connections with other corporate reporting. Clearly labeled Appendices can make it easier to find specific, detailed information."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","It is much easier to understand, as the \"may\" datapoints were confusing, and it was cumbersome to seek out and find the related AR and determine which were required and which were voluntary."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E3; E4","For ESRS E4, NMIG 13 for para. 20, it provides a list of data sources for biodiversity-sensitive areas, and refers to the Annex II definition. While many of the datasets in both descriptions are the same, some differ. E.g., NMIG 13 for para. 20 mentions the STAR metric, but Annex II does not. Annex II mentions Ramsar, but NMIG 13 does not. It would be better to have these consistent.  Additionally, much of the data required for biodiversity sensitive areas is only available through IBAT, which can be prohibitively expensive for smaller companies. If there is a way to make these datasets more accessible, or not to mandate certain private datasets, that would help relieve an undue burden for these companies.  NMIG 14 for para. 20. This is helpful to keep in, to help companies understand that they can use results from their already completed EIAs for determining if the site may have negative impacts on biodiversity sensitive sites.  NMIG 15 for para. 20: The example table is a helpful template for companies to present their information.  NMIG- ESRS E3 NMIG 6 for para. 17: this provides a helpful list of tools that can be used to identify areas at water risk and areas of high water stress."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","In terms of identifying material IROs, there are datasets available and accessible to all companies, even those with small teams and limited resources. The ESRS say that when actual data isn't available, estimates can be used. ENCORE provides industry-level data on nature risks that can help companies prioritize materiality. Rather than say companies don't need to report what they don't have data for, companies should be encouraged to use estimated or industry-level data, and then have a time period in which they need to update with actual data. I agree that it is essential to include a time limit, as we are only 5 years away from 2030 and the 30 by 30 global goal that was set as part of the Kunming-Montreal Global Biodiversity Framework.  I agree that if companies don't have information on upstream or downstream, that can be delayed, although ENCORE can be used for value chain as a starting point. If upstream and downstream are not included, a time limit should be put on that as well."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","22.E4.","Comments on deleted datapoints in ESRS E4","I agree","The related datapoints were merged and the focus of the disclosure was maintained. The voluntary datapoints had been confusing."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","These datapoints do not appear to add an additional burden, and improve the clarity of reporting requirements."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","These datapoints do not add an additional burden, and are added for better alignment with recent EU regulatory developments, or to consolidate other data points."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","I agree that this is outdated. Leveraging the SBTN framework which describes how to set targets would provide better guidance to companies. In addition, the Nature Positive Initiative's pilot of their State of Nature metrics, once complete, may also have guidance on target setting."]
["Survey","Dunya Analytics","User (analyst, data provider, rating agency, etc.)","United States","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Frontierra","Consultant (including software vendor)","United Kingdom","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","We welcome TNFD's proposal1 to consolidate the current nature-related standards (E2-E5) into a single, integrated nature standard and to (i) ensure a structured materiality assessment for nature-related issues; (ii) elevate reference to 'dependencies' on nature; and (iii) streamline and prioritize the number of quantitative nature-related data points. We call on EFRAG to make note of it and apply as possible."]
["Survey","Frontierra","Consultant (including software vendor)","United Kingdom","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E4","We do not support the removal of the ESRS E4 biodiversity and ecosystems metrics metric specifications from the mandatory requirements. This is problematic because standardization is more limited at present than with other metrics. Specifying metrics (now in Non-Mandatory Illustrative Guidance (NMIG) 18-20) within the Standard would give companies the information they need to select and report practical, credible and comparable metrics and would support alignment with the TNFD disclosure metrics. If this does not occur, at the very least, it is important that (i) the NMIG stays attached to the Standard in some form and (i) a process is in place for ensuring updates are made on a timely basis, particularly for guidance on topics where data/tools for reporting are evolving rapidly."]
["Survey","Frontierra","Consultant (including software vendor)","United Kingdom","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the ESRS being simplified in a way that maintains the double materiality approach of the Corporate Sustainability Reporting Directive (CSRD), covering environmental, social and governance topics. This principle of double materiality is vitally important for the reported information to be meaningful for users. It is also essential for the EU to respect its international engagement under the UN CBD Global Biodiversity Framework Target 15."]
["Survey","Frontierra","Consultant (including software vendor)","United Kingdom","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the simplification effort mainly targeting unclear or duplicative requirements, maintaining essential disclosures on environmental metrics and ask EFRAG to maintain that approach in the simplification process.  We also welcome alignment with the draft global consensus metrics on the state of nature, convened by the Nature Positive Initiative. This is important for ensuring metrics are credible, practical and aligned for companies.  We support the simplified standards aligning with core elements of TNFD and encourage EFRAG to continue striving to maintain alignment with other international standards and frameworks, including ISSB and GRI. Improving the interoperability between the requirements in ESRS and the ISSB Standards, to enable companies to use the ISSB Standards as a starting point and 'top up' with specific impact disclosures to achieve compliance with the CSRD/ESRS, is important."]
["Survey","Frontierra","Consultant (including software vendor)","United Kingdom","35.E4-5."," Do you agree with the amendments of this chapter? ","I disagree","The option to report metrics only for locations relevant to existing sustainability targets should be removed or made additional. In order to align with the double materiality concept in ESRS 1 and throughout the standards, metrics should be reported for locations that are material for biodiversity and ecosystems.","E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","IFRS S1 does not specifically prescribe whether or how an entity is required to consider risk mitigation activities when identifying sustainability-related risks that could reasonably be expected to affect an entity's prospects and judgement must be applied. It was noted that this (appropriately) includes the need to apply judgement about how risk mitigation activities that are planned or that are already in place inform the identification of sustainability-related risks. Taking this approach, in some cases the assessment would be net (that is, considering the effects of mitigation) and sometimes gross (that is, before the effects of mitigation). The proposed approach in the ESRS ED prescribes how to consider mitigation, prevention and remediation actions in each situation. This prescriptive approach gives rise to a new risk to interoperability that could affect the scope of sustainability-related matters the respective standards would require information to be provided about."]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","Option 1 would enhance interoperability between ESRS and ISSB Standards and reduce the reporting burden for companies preparing information about anticipated financial effects applying ESRS. However, introducing the relief related to the skills, capabilities and resources available to the company and fully aligning the wordings of the other proportionality mechanisms with that in ISSB Standards (which is not the case in the current proposals) would benefit companies and significantly enhance interoperability between the two sets of standards. In addition, introducing a relief related to the commercial sensitivity of information about opportunities would further enhance interoperability and assist companies."]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","While the content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced, we can enhance interoperability with the ISSB Standards and reduce the reporting burden for those applying ESRS by making the incremental quantitative information about a company's anticipated financial effects in paragraphs 40, 41 and 42 of the proposed changes to ESRS E1 (proposed Disclosure Requirement E1-11) optional.",null,null,""]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","To further enhance interoperability with the ISSB Standards:  (i) Allow measurement choices per the GHG Protocol and IFRS S2: The draft ESRS E1 has proposed the use of the financial control as the default organisational boundary in measuring GHG emissions. However, if such information fails to convey a fair presentation, ESRS E1 requires additional disclosure of Scope 1 and 2 GHG emissions based on operational control as defined in the GHG Protocol. This creates misalignment in classification and measurement approaches with current GHG Protocol and IFRS S2 (where companies are permitted to determine their organisation boundaries in accordance with options as prescribed by GHG Protocol – equity method, operational control and financial control). As such, we recommend EFRAG to align the measurement choices in ESRS E1 with GHG Protocol and IFRS S2, to reduce risks of differences between the frameworks / standards.  (ii) Remove specific value chain information regarding leased assets: EFRAG has proposed to add a new section on the inclusion of value chain information regarding leased assets which adds a level of specificity that does not exist in the ISSB Standards. This proposal introduces the risk of new application differences between ESRS, ISSB Standards, and the GHG Protocol.  (iii) Fully incorporate the IFRS reliefs: To allow omitting of commercially sensitive information about opportunities, Scope 3 GHG emissions when impracticable, and quantitative financial effects when the undertaking does not have the necessary skills or will be required to incur inordinate expenditure to acquire such skills or expertise."]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We are a global investor with portfolio spanning across geographies and industries. As a financial investor, we expect material decision useful information from our investees that is comparable. Many of our investees operate in jurisdictions that require the use of standards that are aligned with the ISSB Standards.   The most effective way to ensure efficient reporting between the EU and international reporting regimes would be to enable companies to use the ISSB Standards as a starting point and 'top up' with specific impact disclosures to achieve compliance with the CSRD/ESRS.   In the absence of equivalence or alternative compliance, a company will need to navigate between two sets of standards to comply with both the CSRD/ESRS and the ISSB Standards. To do so effectively the respective standards need to be interoperable. We believe closer alignment of ESRS with ISSB Standards will reduce duplicative reporting obligations for both EU and non-EU companies, and support the EU aims of high ESG standards while ensuring attractiveness of the EU as an investment destination.  Furthermore, competing disclosure regimes will introduce difficulties to a global investor to compare information provided by investees that are subject to different regimes."]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","35.ESRS1_1."," Do you agree with the amendments of this chapter? ","I agree","Enabling companies reporting in compliance with ESRS to reference the IFRS Industry-based guidance facilitates efficiency for companies and provides decision-useful information for investors.","ESRS1","1. ESRS Standards, reporting areas and drafting conventions",""]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","35.ESRS1_8.2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Paragraph 107 and 108 of draft ESRS 1 describes the technical material issued by the ISSB as additional disclosures that need to be clearly identified and presented in a way that do not obscure material information. This appears to contradict paragraph 11 of draft ESRS 1 that allows company to use reporting standards such as IFRS industry-based guidance to provide entity-specific disclosures.  To enhance clarity, paragraph 107 and 108 of draft ESRS 1 can be re-drafted to enable companies to use the ISSB Standards as a starting point and 'top up' with specific disclosures to achieve compliance with CSRD/ESRS. We believe such closer alignment of ESRS with ISSB Standards will reduce duplicative reporting obligations and administrative burden for both EU and non-EU companies.","ESRS1","8.2 Presentation of additional information included in the sustainability statement",""]
["Survey","Temasek International Pte. Ltd.","Asset manager/Investor","Singapore","35.E1-8."," Do you agree with the amendments of this chapter? ","I disagree","To further enhance interoperability and reduce the differences between the requirements of the GHG Protocol, ESRS and IFRS S2, EFRAG should allow the measurement choices per the GHG Protocol and IFRS S2.","E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","ESRS para. 48(a) and AR 17 provide practical approach and AR 18 and AR 19 allows assessment of severity/magnitude and likelihood only for IROs whose materiality is not yet clear. This avoids unnecessary reassessment of elements already determined to be material or immaterial. However, necessary additional clarifications in the DMA updating process, where DMA should be proportionate to changes in circumstances, ensuring companies can leverage in previous assessment if conditions/IROs haven't changed. Also, need of illustrative examples of when AR 18–19 apply."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","Disregarding existing mitigation measures when assessing the materiality of potential impacts will lead to disproportionate reporting obligations if implemented actions to control severity are in place. This conflicts with the core purpose of using materiality as a reporting filter, which is to focus on issues that truly matter to the company and its stakeholders. Forcing to report extensively on such cases would dilute the relevance of disclosures and significant impacts. Guidance must include examples illustrating when mitigated potential impacts no longer meet the materiality threshold. Misleading guidance on how to consider remediation/mitigation/prevention actions in assessing materiality of negative impacts between ESRS 1 para. 34 and appendix C. As result of the above, in agreement with Appendix C (report potential impacts after prevention or mitigation actions if it remains material, and report the significant ongoing action for as long as it is necessary to manage the residual material impact.)."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","In agreement with the changes to improve readability, conciseness and connectivity, specifically allowing disclosures at a higher level of aggregation than individual material IROs, where this reflects how IROs are actually managed."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","In disagreement with removing narrative disclosures while introducing new quantitative datapoints. Narrative disclosures generally build on existing management information, while quantitative datapoints often require entirely new systems, processes, and controls, creating significant additional costs and complexity."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","Further clarity regarding the \"undue cost of effort relief\" implications in terms of audit? How does this need to be evidenced?"]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","In disagreement with the absense of time limit for reliefs, as this could create uneven competitive position. The aim should be to enhance methodologies and improve data availability over time. This can be achieved by setting a time limit on reliefs, thereby encouraging actions towards this direction."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Option 2 allows companies to disclose the anticipated financial effects without compromising their financial position, particularly in cases where calculations rely on long-term assumptions that may be unreliable and involve high uncertainty. Moreover, option 2 gives companies confidence that commercially sensitive information will not be disclosed."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","Need for further guidance on the measurement of anticipated financial effects, particularly through specific examples illustrating the presentation of potential liabilities, such as those related to climate transition risks or stranded assets, in case quantification is required as methodologies are neither well-defined nor robust.",null,null,""]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.E1.","Comments on deleted datapoints in ESRS E1","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.S1","Comments on deleted datapoints in ESRS S1","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.S4","Comments on deleted datapoints in ESRS S4","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","22.G1","Comments on deleted datapoints in ESRS G1","I agree","Agree with the decrease of mandatory DPs that allow companies to reduce reporting burden."]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","Need for further clarification on the consequences of the fair presentation approach. What is the relationship between materiality principle and fair representation approach?"]
["Survey","Ryanair","Preparer (non-financial preparing a sustainability report)","Ireland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","This change is not supported."]
["Survey","UAM","Academia","Spain","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","UAM","Academia","Spain","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","UAM","Academia","Spain","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","UAM","Academia","Spain","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","UAM","Academia","Spain","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","UAM","Academia","Spain","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","UAM","Academia","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","UAM","Academia","Spain","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","UAM","Academia","Spain","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","UAM","Academia","Spain","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","UAM","Academia","Spain","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","UAM","Academia","Spain","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","UAM","Academia","Spain","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","UAM","Academia","Spain","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","UAM","Academia","Spain","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","It seems financial institutions (including the Basel agreement) are key actors in the energetic transition needed to mitigate climate change"]
["Survey","UAM","Academia","Spain","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","I am unsure if country level is the right scope for reporting metrics. It is better than company level but can also be tricky if does not take into account planetary scope"]
["Survey","UAM","Academia","Spain","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","UAM","Academia","Spain","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","UAM","Academia","Spain","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","UAM","Academia","Spain","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree"]
["Survey","UAM","Academia","Spain","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","UAM","Academia","Spain","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UAM","Academia","Spain","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We partially agree but see room for improvement in the following areas:  Greater clarity on how to evaluate the criteria based on the proposed structure (e.g., severity). More flexibility to apply self-selected criteria, provided these are transparently communicated to readers. An alternative, more unconventional approach could be to make DMA reporting entirely voluntary. It could still serve as a tool for determining the reporting scope but without requiring the results to be reported."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","In its current form, the explanation does not provide sufficient clarity on how remediation actions are factored into the impact assessment, particularly when it comes to their placement on, for example, a 1-5 scale.  Another challenge is the consideration of national regulations. For instance, E2 is subject to strict regulation in Germany, with clearly defined thresholds for aspects such as air pollutants. How is this to be incorporated into the impact assessment?"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","In our opinion, it remains unclear whether an entity has the flexibility to report the standards within the ESG framework in an order of their choosing. This also applies to structuring the narrative along the order of the ESRS paragraphs/disclosure requirements.  Furthermore, the option to link information to external documents could significantly enhance the conciseness and usability of the report.  Lastly, a clarification on the use of graphs and the ability to tag information within graphs—particularly in the context of ESEF tagging—would be highly beneficial."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","There is a lack of clarification that the permanent use of estimates is allowed and that the extent of uncertainty in the estimation is not decisive for reporting or in the audit.  Additionally, the current extensive requirement to individually document the data collection and calculation method for each metric is impractical. We wish it would be possible to shorten this."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The new Paragraph 92 does not yet clearly specify whether a 'partial scope of calculation' can also apply to a shifted fiscal year. Due to other national and European regulations such as the IED or EPRTR, we are required to provide reports to local/national authorities on a calendar-year basis. It should be possible to use these calendar-year values even for a shifted fiscal year; otherwise, there would be significant conversion effort as well as confusion caused by contradictory reporting of the same datapoints for our stakeholders."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.E5.","Comments on deleted datapoints in ESRS E5","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","22.G1","Comments on deleted datapoints in ESRS G1","I partially agree and partially disagree","Fundamentally, the new structure presents us with the challenge of a significant one-time effort to re-tag existing reporting content and review it for its alignment with the new requirements. Therefore, it would be preferable to retain the current structure but convert many 'shall' data points into 'may' data points.  If this is not feasible, we would welcome a transition phase during which entities could choose between the old and the new ESRS for a period of 1-2 years."]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","E5-5: In general, the final destination of waste is usually clear in Germany; however, this is not always the case at every stage of the process. When waste is managed by third-party waste operators, the entity often only receives an invoice indicating the quantity of waste handled, without any transparency regarding the final destination or the disposal method. Should waste falling into this category be included in this data point?"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","MVV Energie AG","Preparer (non-financial preparing a sustainability report)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We would welcome a clarification that the report can be reviewed not only by auditors but also by independent third-party reviewers.  Furthermore, we would like to emphasize once again the importance of addressing the uncertainty related to calendar-year-based data for entities with a shifted fiscal year. It is essential to ensure alignment between regulations requiring reporting to authorities for monitoring purposes and external reporting for transparency."]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the ESRS being simplified in a way that maintains the double materiality approach of the Corporate Sustainability Reporting Directive (CSRD), covering environmental, social and governance topics. This principle of double materiality is vitally important for the reported information to be meaningful for users. It is also essential for the EU to respect its international engagement under the UN CBD Global Biodiversity Framework Target 15."]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the simplification effort mainly targeting unclear or duplicative requirements, maintaining essential disclosures on environmental metrics and ask EFRAG to maintain that approach in the simplification process.  We also welcome alignment with the draft global consensus metrics on the state of nature, convened by the Nature Positive Initiative. This is important for ensuring metrics are credible, practical and aligned for companies."]
["Survey","Ecopreneur.eu - The European Sustainable Business Federation","Business association (other than association of financial institution)","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We support the simplified standards aligning with core elements of TNFD and encourage EFRAG to continue striving to maintain alignment with other international standards and frameworks, including ISSB and GRI. Improving the interoperability between the requirements in ESRS and the ISSB Standards, to enable companies to use the ISSB Standards as a starting point and 'top up' with specific impact disclosures to achieve compliance with the CSRD/ESRS, is important."]
["Survey","Business for Nature","Business association (other than association of financial institution)","United States","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","We welcome TNFD's proposal to consolidate the current nature-related standards (E2-E5) into a single, integrated nature standard and to (i) ensure a structured materiality assessment for nature-related issues; (ii) elevate reference to 'dependencies' on nature; and (iii) streamline and prioritize the number of quantitative nature-related data points. We call on EFRAG to make note of it and apply as possible."]
["Survey","Business for Nature","Business association (other than association of financial institution)","United States","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E4","We do not support the removal of the ESRS E4 biodiversity and ecosystems metrics metric specifications from the mandatory requirements. This is problematic because standardization is more limited at present than with other metrics. Specifying metrics (now in Non-Mandatory Illustrative Guidance (NMIG) 18-20) within the Standard would give companies the information they need to select and report practical, credible and comparable metrics and would support alignment with the TNFD disclosure metrics. If this does not occur, at the very least, it is important that (i) the NMIG stays attached to the Standard in some form and (i) a process is in place for ensuring updates are made on a timely basis, particularly for guidance on topics where data/tools for reporting are evolving rapidly."]
["Survey","Business for Nature","Business association (other than association of financial institution)","United States","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We support the simplified standards aligning with core elements of TNFD and encourage EFRAG to continue striving to maintain alignment with other international standards and frameworks, including ISSB and GRI. Improving the interoperability between the requirements in ESRS and the ISSB Standards, to enable companies to use the ISSB Standards as a starting point and 'top up' with specific impact disclosures to achieve compliance with the CSRD/ESRS, is important."]
["Survey","Business for Nature","Business association (other than association of financial institution)","United States","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the ESRS being simplified in a way that maintains the double materiality approach of the Corporate Sustainability Reporting Directive (CSRD), covering environmental, social and governance topics. This principle of double materiality is vitally important for the reported information to be meaningful for users. It is also essential for the EU to respect its international engagement under the UN CBD Global Biodiversity Framework Target 15."]
["Survey","Business for Nature","Business association (other than association of financial institution)","United States","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the simplification effort mainly targeting unclear or duplicative requirements, maintaining essential disclosures on environmental metrics and ask EFRAG to maintain that approach in the simplification process.   We also welcome alignment with the draft global consensus metrics on the state of nature, convened by the Nature Positive Initiative. This is important for ensuring metrics are credible, practical and aligned for companies."]
["Survey","Business for Nature","Business association (other than association of financial institution)","United States","35.E4-5."," Do you agree with the amendments of this chapter? ","I disagree","The option to report metrics only for locations relevant to existing sustainability targets should be removed or made additional. In order to align with the double materiality concept in ESRS 1 and throughout the standards, metrics should be reported for locations that are material for biodiversity and ecosystems.","E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","The amendments support more relevant reporting, but there remain some areas where reporting requirements remain onerous and lack relevance, in particular ESRS 1.10; 1.11; 5.2; ESRS E1 AR2 For Para 14(a); E1-7 (38 amended); AR17 for para 28 AR 32 amended; ESRS E2 AR 5 for para.16 (b); ESRS E5 !18; ESES S1 -13 40C; ESRS S2 8 (b) and (d). See section 3 of questionnaire for details"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Refer to detailed responses in Part 3 of this survey"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Agee that NMIG should not be included in the delegated act to avoid triggering additional reporting burden"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Given the nature of anticipated financial effects, it is very difficult to provide an accurate quantitative assessment of financial effects, especially as this is often very dependent on the specific scenario analysis used. Making this a requirement raises a high risk of qualitative assessments simply being turned into quantitative assessments, with the resulting information not being useful"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","The items highlighted represent a very onerous burden to quantitatively estimate with any accuracy and are very dependent on the climate scenario used. Without specific requirement on which scenarios shall be used, reporters will produce data based on significantly varying assumptions, and the value of information will be limited as it will not be possible to compare different reporters on a like-for-like basis"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","ESRS E3 / E4 Whilst these items are generally applicable to onshore operations, the nature of marine operations means that the impact of direct water withdrawals from the ocean for potable water production and operational use is very limited, as is discharge. A note in the guidance should be made to explain this to data users, and the ESRS should allow operations that abstract and return water directly to the marine environment to explain the exact nature of this operation"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Disagree with E2-4. The generation of secondary microplastics though equipment wear is extremely difficult to calculate, even qualitatively. Microplastic generation should be defined in terms of equipment manufacturer's plastic content and manufacturer's end of life treatment. Making this a general requirement for all organization's risks significant double counting, and the lack of a defined qualitative assessment standards or methodologies will cast doubt on the ability to compare results across companies. This requirement should be removed"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","_Complex estimates are common to all sectors. Banks are no exception. Exception only for financial institutions would result in an unlevel playing field for other sectors.  Intensity only targets should be permitted for all reporters following the same rationale given for this exemption by the finacial sector"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","Collective bargaining agreements are country specific. Data should be readily available for enterprises working in multiple countries through core HR systems"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","Agreement is contingent on the methodology, which must recognize the economic situation in LDCs outside the EEA, and not penalize companies providing adequate wages in the local context if they are not in line with minimum wages in the EU"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Whilst alignment with SBTN is welcome, the standards and guidance must reflect that that the sector standards for SBT in the oil and gas industry are paused. Unless this standard is released, the AR must state that this only applies where recognised sector SBTs exist"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to response in part 3"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Annika Eliasson Academic E-learning","User (analyst, data provider, rating agency, etc.)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","I welcome TNFD's proposal to consolidate the current nature-related standards (E2- E5) into a single, integrated nature standard and to (i) ensure a structured materiality assessment for nature-related issues; (ii) elevate reference to 'dependencies' on nature; and (iii) streamline and prioritize the number of quantitative nature-related data points. I call on EFRAG to make note of it and apply as possible."]
["Survey","Annika Eliasson Academic E-learning","User (analyst, data provider, rating agency, etc.)","Sweden","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","I welcome TNFD's proposal to consolidate the current nature-related standards (E2- E5) into a single, integrated nature standard and to (i) ensure a structured materiality assessment for nature-related issues; (ii) elevate reference to 'dependencies' on nature; and (iii) streamline and prioritize the number of quantitative nature-related data points. I call on EFRAG to make note of it and apply as possible."]
["Survey","Annika Eliasson Academic E-learning","User (analyst, data provider, rating agency, etc.)","Sweden","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E4","I do not support the removal of the ESRS E4 biodiversity and ecosystems metrics metric specifications from the mandatory requirements. This is problematic because standardization is more limited at present than with other metrics. Specifying metrics (now in Non-Mandatory Illustrative Guidance (NMIG) 18-20) within the Standard would give companies the information they need to select and report practical, credible and comparable metrics and would support alignment with the TNFD disclosure metrics. If this does not occur, at the very least, it is important that (i) the NMIG stays attached to the Standard in some form and (i) a process is in place for ensuring updates are made on a timely basis, particularly for guidance on topics where data/tools for reporting are evolving rapidly."]
["Survey","Annika Eliasson Academic E-learning","User (analyst, data provider, rating agency, etc.)","Sweden","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","I welcome the ESRS being simplified in a way that maintains the double materiality approach of the Corporate Sustainability Reporting Directive (CSRD), covering environmental, social and governance topics. This principle of double materiality is vitally important for the reported information to be meaningful for users. It is also essential for the EU to respect its international engagement under the UN CBD Global Biodiversity Framework Target 15."]
["Survey","Annika Eliasson Academic E-learning","User (analyst, data provider, rating agency, etc.)","Sweden","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","I welcome the simplification effort mainly targeting unclear or duplicative requirements, maintaining essential disclosures on environmental metrics and ask EFRAG to maintain that approach in the simplification process. I also welcome alignment with the draft global consensus metrics on the state of nature, convened by the Nature Positive Initiative. This is important for ensuring metrics are credible, practical and aligned for companies."]
["Survey","Annika Eliasson Academic E-learning","User (analyst, data provider, rating agency, etc.)","Sweden","35.E4-5."," Do you agree with the amendments of this chapter? ","I disagree","The option to report metrics only for locations relevant to existing sustainability targets should be removed or made additional. In order to align with the double materiality concept in ESRS 1 and throughout the standards, metrics should be reported for locations that are material for biodiversity and ecosystems.","E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","The simplified ESRS allow more conciseness but the AR 24 for para.  28(a) could be amended to avoid repetition of description of the material impacts, risks and opportunities. This mandatory datapoint should be suppressed: \"If the undertaking exercises this option, it shall still  present a concise description of its material impacts, risks and opportunities alongside  its disclosures prepared in accordance with IRO-2.\""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1; S1","Some possibilities mentioned in the NMIG change the mandatory requirement mentioned in the draft ESRS. For example, NMIG 30 for paras.38 (a)(b) Calculation training hours and development data, the possibility to exclude inactive employees in the denominator should still be part of the ESRS. Indeed, this is not a voluntary additional datapoint but a possible change in a calculation that shall be done. If not included in the ESRS themselves, this might create issues with auditors if NMIG is not included in the CSRD."]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","some \"shall\" datapoints should still be suppressed"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","ESRS E4 Transition plan: this should remain a voluntary datapoint G1 business conduct: this shall datapoint recreates an additional burden and this is sensitive information that should not be mandatory. The existing mandatory disclosures were sufficient"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","Though we understand the intent, this additional wording might create a lot of discussions with the auditors. The objective of \"reducing the unnecessary reported information and the documentation needed to show that omitted datapoints are not material\" can be achieved by completing the double materiality chapter in ESRS 1 (as this is already done in the draft)."]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","For all sectors this is an issue to disclose absolute GHG emissions target as it leads to disclose long term forecast business growth, which is often confidential information. Companies should have the possibility to choose between intensity and absolute targets in their reports, from financial or from other sectors as well."]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","As it states, the datapoint will still trigger very different interpretations from one Company to the other. It would be more straightforward to have each year a list of adequat wages per country so that all companies have a common reference. If this is not possible to create a common reference, then the suppression of this datapoint seems more relevant."]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree","Some more simplification should be brought to other datapoints that are part of the SFDR and this has blocked simplification - S1-15 unadjusted gender pay gap for example. SFDR reglementation should be also simplified / clarified if necessary."]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-5."," Do you agree with the amendments of this chapter? ","I disagree","Same threshold should be maintained as previous disclosures: \"countries in which the undertaking has 50 or more employees representing at least 10% of its total number of employees\". Because the proposed change impose unnecessary administrative burden for many countries. If the fear is to miss some countries with a high number of employees, maybe there could be an additional requirement that all countries with more than 3000 headcounts should be reported for example.","S1","Disclosure Requirement S1-5 - Characteristics of the undertaking’s employees",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-6."," Do you agree with the amendments of this chapter? ","I disagree","This datapoint should be suppressed as this will create many discussions with definitions and auditors only to provide a number.","S1","Disclosure Requirement S1-6 - Characteristics of non-employees in the undertaking’s own workforce",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-7."," Do you agree with the amendments of this chapter? ","I disagree","This should be reported for countries with significant employment only as the burden of data gathering is huge for small countries. For a practical point of view, we should not have by country for EEA and by region for outside EEA as this makes things more complex. The reporting should be made for countries with significant employment for all geographies.","S1","Disclosure Requirement S1-7 - Collective bargaining coverage and social dialogue",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-10."," Do you agree with the amendments of this chapter? ","I disagree","First, unemployment consideration should be excluded from this Disclosure Requirement as this is linked with public policies of each country and does not rely on the Company. Second, due to the reporting burden of this datapoint, the information should be gathered only for countries with significant employment. Third, the definitions should be clarified. Indeed, for sickness, what is the length that should be considered: starting from one day, is this a sufficient period? Same thing for maternity leave, some more precision should be brought to what could be considered as a protection.","S1","Disclosure Requirement S1-10 - Social protection",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-12."," Do you agree with the amendments of this chapter? ","I disagree","For regular performance review, this is now specified that the denominator should be the number of employees reported in S1-5. This is not meaningful as employees hired recently are not eligible to performance review. This was better to let each group explain how they perform their calculation based on their internal standards / procedures.","S1","Disclosure Requirement S1-12 - Training and skills development metrics",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-14."," Do you agree with the amendments of this chapter? ","I disagree","This Disclosure Requirement should remain mandatory only for countries with significant employment.","S1","Disclosure Requirement S1-14 - Work-life balance metrics",""]
["Survey","Technip Energies","Preparer (non-financial preparing a sustainability report)","Netherlands","35.S1-15."," Do you agree with the amendments of this chapter? ","I disagree","Even if required by SFDR, a worldwide calculated gender pay gap does not make any sense and does not provide useful information. Only a gender pay gap calculated and disclosed per country makes sense. So this should be requested per country for countries with significant employment.","S1","Disclosure Requirement S1-15 - Remuneration metrics",""]
["Survey","Brancheforeningen Cirkulær","Business association (other than association of financial institution)","Denmark","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree"]
["Survey","Brancheforeningen Cirkulær","Business association (other than association of financial institution)","Denmark","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","The recovery definition proposed in Annex II p. 27 and its application to ESRS E5, paragraph 18 on waste, do not align with existing EU legislation. The Waste Framework Directive (2008/98/EC, Article 3(15) and Annex II), which is the cornerstone of EU waste management legislation, defines recovery as: \"any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy. Annex II sets out a non-exhaustive list of recovery operations.\" As currently drafted, the reporting framework would lead to inaccurate reporting, as it would be unclear where to report incineration with energy recovery (R1): it is explicitly excluded from the ESRS definition of \"recovery\", but is not a disposal operation and therefore should not be reported under \"waste directed to disposal\". This would misrepresent actual waste treatment performance, create inconsistencies in EU statistics and compliance reporting, and result in incorrect financial disclosures by companies, since waste treatment pathways directly affect cost allocations, liabilities, and sustainability performance indicators.   The stated goal of the Amended ESRS consultation is simplification and greater usability without compromising EU objectives. Introducing a definition that conflicts with existing law instead increases reporting complexity, as companies would face two contradictory classifications. To ensure alignment with existing EU legislation and avoid unnecessary burdens, we propose that: •\tThe definition of \"recovery\" in Annex II should be amended to replicate or explicitly reference the definition provided in Article 3(15) of the Waste Framework Directive. •\tESRS E5 §18 should clearly reflect that incineration with energy recovery (R1) is a recovery operation, consistent with EU law. For example, \"iii. other recovery operation, including incineration with energy recovery\""]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Still not 100% clear how to assess severity of actual negative impacts in light of prevention/mitigation measures (not remediation, for which is clear that gross approach should be used). Paragraph 34 says: \"When assessing the materiality of actual negative impacts, the severity of the impact shall be evaluated considering the outcomes of any mitigation or prevention measures implemented before the impact occurred\". So, if the impact is x and prevention/mitigation actions outcome is y, the severity should be assessed as z=x-y if I'm not mistaken. But this wasn't clear enough the first time I read it, it seemed confusing especially when reading appendix C tables. For my understanding this is a net assessment of the severity of actual negative impacts in light of prevention/mitigation measures, but this point is not included in the Appendix C table since the table for actual negative impacts take into consideration only remediation actions and not prevention/mitigation. This should be clarified somehow, possibly by outlining the difference between what a remediation, mitigation, and prevention measure entail or by providing some explanatory examples for each type of actions in the DMA section of the Non-Mandatory Illustrative Guidance or in the Application Requirements of the relevant section."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","It is mentioned in the application requirements of SBM-3 that the interaction between material IROs and strategy and business model is also prescribed by IRO-2 par 28(a). In this case SBM-3 seems redundant also given the fact that the description of strategy and business model is prescribed in SBM-1. The few SBM-3 datapoints could then be incorporated into SBM-1 or be incorporated as application requirements of IRO-2."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","Data lacking in quality is indeed in contrast with the \"fair representation\" principle. In particular with verifiability and comparability. Thus there would be no relevant loss of information if omitted."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","I agree with option 1: leaving the possibility to report quantitative information on a voluntary basis would undermine the objective of the Green Deal considering that the CSRD proposed new scope would exclude from reporting the vast majority of EU businesses. Disclosing quantitative metrics on anticipated financial effects is crucial in allowing the most efficient capital allocation towards streams that are more sustainable instead on businesses that have a high environmental risk profile due to their lack of ambitions and actions against environmental issues (or that just present qualitative claims that are not substantiated with quantitative data, a case for which option 1 is better since it prescribes specific conditions under which quant. data can be omitted). In essence, giving companies too much room for deciding whether or not providing quantitative data by limiting the mandatory reporting of such information to qualitative assumptions on anticipated financial effects only would result not only in loss of information but also in loss of quality information, since there would be no hard data to back up qualitative claims (no consistent verifiability of data). Qualitative  information that is not backed up by quantitative data can be misleading."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","Some data points might be indeed burdensome but if option 1 from the previous question will be followed then it allows the right amount of flexibility in disclosing this type of information which is quite relevant for financial actors.",null,null,""]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets: both metrics are needed to have a more comprehensive outlook on financial institutions emissions profile since GHG intensity metric can change depending on whether the numerator or denominator changes. Absolute emission values might serve as a validation of actual ghg reduction."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","For E1-5 par. 40 to 43 I understand the information can be found elsewhere or derived from other indicators but allowing an easier identification of the metric might be better especially for users of the sustainability statement. Same logic for E1-6 para 53 to 55: info can be derived from other metrics but having gross GHG emissions intensity might be a good validation of the metrics from which it can be derived. I agree with the rest of the reasoning especially for moving certain topical paragraphs to ESRS 2 to avoid repetitions or the deletion of certain paragraphs that indeed would have been redundant (especially for the PAT related paragraphs)."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","AR 26 b) may be worded as: size and site of newly created habitats that didn't originally exist; AR26 c) may be worded as: number or percentage of projects / sites where the undertaking has contributed to improve an ecosystem's capacity in maintaining its essential functions, diversity, and environmental processes (known as \"ecological integrity\")"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","How payment practices towards SMEs are handled should be included at least in the \"G1-1 – policies related to business conduct\". Otherwise, this issue would be easily overlooked since \"payment practices\" are only mentioned at the beginning of the amended G1 as being a sub-topic. Reiteration in this case can be helpful to pinpoint the relevance of the sub-topic. Especially since SMEs constitute the largest share of businesses in the EU."]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","One Click ESG","Consultant (including software vendor)","Netherlands","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","It should include a simple methodology for classifying impacts, risks and opportunities and defining a scale so that double materiality assessments carried out by different companies can be compared. There is a need to create a more practical tool."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Significant improvement"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E4","It would be interesting if NMIG 2 for. 15 were described in Amendments to ESRS E4."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Quantitative information is often too important to omit and, as it is generally more engaging and visually effective in a report, it should be given priority."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","There should be more content and support for the  probability of  occurrence, as in certain cases it is difficult to identify.",null,null,""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.E5.","Comments on deleted datapoints in ESRS E5","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","22.G1","Comments on deleted datapoints in ESRS G1","I partially agree and partially disagree","Some voluntary data points should be retained to provide companies with guidance on how to go the extra mile in their reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Financial institutions can provide transparency and foresight to investors by disclosing detailed intensity-based targets, explaining the methodologies and assumptions underpinning them, aligning their pathways with recognised climate scenarios, and reporting regularly on sectoral exposures and transition strategies."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The increase in the number of countries reporting for these two disclosures will encourage other countries outside the EU to also start collecting this type of information and looking at sustainability reporting."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","I do not agree with the removal of fatalities from the scope of SFDR PAI Indicator 3. Excluding such a critical measure undermines transparency and weakens the ability to assess the full impact of undertakings on workers' rights and wellbeing."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","I do not agree with the deletion of the voluntary datapoint on the adjusted gender pay gap. While the unadjusted ratio provides a broad picture, the adjusted metric by employee category offers more meaningful insights into structural inequalities within organisations and should remain available to enhance transparency and comparability."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","The deletion of explicit datapoints on payment practices reduces transparency on how undertakings treat their suppliers, particularly SMEs, and weakens the ability to assess whether companies are supporting fair and sustainable business relationships in line with the CSRD's objectives."]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E1-1."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-1 - Transition plan for climate change mitigation",""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E1-5."," Do you agree with the amendments of this chapter? ","I agree","Mention the connection with CDP and SBTI.","E1","Disclosure Requirement E1-5 - Actions and resources in relation to climate change",""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E1-8."," Do you agree with the amendments of this chapter? ","I agree",null,"E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E4-1."," Do you agree with the amendments of this chapter? ","I agree",null,"E4","Disclosure Requirement E4-1 - Transition plan for biodiversity and ecosystems",""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E4-2."," Do you agree with the amendments of this chapter? ","I agree",null,"E4","Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems",""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E4-3."," Do you agree with the amendments of this chapter? ","I agree",null,"E4","Disclosure Requirement E4-3 - Actions and resources related to biodiversity and ecosystems",""]
["Survey","Aliados Consulting","Consultant (including software vendor)","Portugal","35.E4-5."," Do you agree with the amendments of this chapter? ","I agree",null,"E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We welcome TNFD's proposal1 to consolidate the current nature-related standards (E2-E5) into a single, integrated nature standard and to (i) ensure a structured materiality assessment for nature-related issues; (ii) elevate reference to 'dependencies' on nature; and (iii) streamline and prioritize the number of quantitative nature-related data points. We call on EFRAG to make note of it and apply as possible."]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E4","We do not support the removal of the ESRS E4 biodiversity and ecosystems metrics metric specifications from the mandatory requirements. This is problematic because standardization is more limited at present than with other metrics. Specifying metrics (now in Non-Mandatory Illustrative Guidance (NMIG) 18-20) within the Standard would give companies the information they need to select and report practical, credible and comparable metrics and would support alignment with the TNFD disclosure metrics. If this does not occur, at the very least, it is important that (i) the NMIG stays attached to the Standard in some form and (i) a process is in place for ensuring updates are made on a timely basis, particularly for guidance on topics where data/tools for reporting are evolving rapidly."]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the ESRS being simplified in a way that maintains the double materiality approach of the Corporate Sustainability Reporting Directive (CSRD), covering environmental, social and governance topics. This principle of double materiality is vitally important for the reported information to be meaningful for users. It is also essential for the EU to respect its international engagement under the UN CBD Global Biodiversity Framework Target 15."]
["Survey","BeeOdiversity","Consultant (including software vendor)","Belgium","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the simplification effort mainly targeting unclear or duplicative requirements, maintaining essential disclosures on environmental metrics and ask EFRAG to maintain that approach in the simplification process.  We also welcome alignment with the draft global consensus metrics on the state of nature, convened by the Nature Positive Initiative. This is important for ensuring metrics are credible, practical and aligned for companies."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The overall simplification of Chapter 3 is welcome. We find the new chapter 3.5. with practical considerations particularly helpful, as it has a potential to relieve large portion of the burden undertakings faced performing their materiality assessments. However we have several comments to changes we don't agree with: (1) The materiality of information principle should not be applicable to ESRS 2, as it may result in omitting fundamental information required in sustainability statements, such as on the DMA process and its results, or the governance over sustainability matters, and details on the undertaking's business model and strategy. The principle of materiality of information is highly judgmental and should be applied with caution. (2) Undertaking should not be allowed to include non-material information in sustainability statements, as this will obscure material information. Companies have many other means to communicate to their stakeholders non-material sustainability related information and there is no need to include these information in official, regulated annual statements. (3) Summarizing the list of topics in current Appendix A to only two-level structure is not very helpful, it was more useful as a three-level structure. Maintaining a three-level structure would not add any burden, as the list illustrative only. We also propose to add for clarity some changes in the list: (a) In \"Climate change\": add \"Loss and damage\" (b) In \"Circular economy and resource use\": add \"Product and service design related to circular economy principles\" (c) In \"Climate change\" replace \"Energy\" with \"Energy, including use of fuels and energy efficiency\" (4) The wording in par. 46 should be amended to reduce the risk of some companies declaring certain topics immaterial without due assessment. We propose the following wording: \"The undertaking (…) and opportunity, however any exclusions must be clearly justified with reasoning and may be documented.\""]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Adding Annex C may provide much needed clarity for undertakings performing their DMAs. However, several elements of the Annex need to be amended. If the intention is to streamline reporting by allowing mitigated impacts to be excluded, the standard should state that such exclusion is only permitted if the impacts and the related mitigation actions were disclosed in a previous report – and that these impacts may be referenced rather than repeated. Under no circumstances should the standard include statements such as 'in principle, no need to report on impact.' Such wording would create major gaps and undermine the reliability and comparability of the materiality assessment. \"If an impact occurred in the reporting period and no remediation action has been taken\" The wording \"If an impact occurred\" suggests that to identify a topic as actual negative, \"something\" would need to happen. E.g. an accident. In practice, for a manufacturing company it is commonly understood that \"employee health and safety\" is an actual material topic regardless of whether any accidents occur. In reference to par. 36 If successfully remediated negative impacts e.g. On employee health and safety do not become positive impacts, then does the topic become non-material? The sentence in the table of the Appendix C suggests that the topic becomes immaterial: \"If the potential impact was material within the reporting year, but prevention or mitigation action has been taken before the reporting date such that the impact no longer exists (…) in principle no need to report the impact, as it is not material.\"  In practice, a manufacturing company that manages employee health and safety effectively, with no incidents or accidents occurring, might classify this topic as immaterial, despite the substantial resources required to maintain it. In a logical approach, this does not make sense."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We agree with most of the changes introduced in relation to interactions between ESRS 2 and topical standards. However the requirement to disclose whether the undertaking plans to implement policies, actions and targets for a material topic, and in which timeframe, should remain as a \"shall\". Sustainability statements don't only document the past, but are also future-oriented. Allowing laggards in sustainable transition to remain silent on their material topics that have not been managed gives them an unjustified competitive advantage in relation to companies that are more advanced in managing sustainability matters. It should be the other way round. Requiring companies to disclose this information (on plans regarding adoption of PATs) is not burdensome, as all the information is readily available in-house."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We don't have comments regarding the contents of particular elements of the NMIG, only comments regarding its status. We propose (at the Commission's discretion) choosing only one of the following two options: (A)\tInclusion of the contents of the NMIG into the Delegated Act. In this case each element of the NMIG should be included in the main body of each standard, in a clearly separable way, right after the applicable DR and AR. In this way, the report preparer would read in one place the disclosure requirement, the corresponding application requirement (in case it exists) and the corresponding non-mandatory illustrative guidance (in case it exists) (B)\tLeaving the contents of the draft NMIG for EFRAG to implement it in a series of Implementation Guidance documents to be issued in the future. Both options result in an understandable structure of the standards and their accompanying documents. Development of NMIG as another layer of documents, besides the mandatory standards and the non-mandatory EFRAG IGs may lead to further confusion among report preparers, users and auditors."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","Simplification of ESRS, restructuring of the standards, elimination of two thirds of datapoints, including all \"may\" datapoints that created confusion is the main relief report preparers receive with the set of revised ESRS. Unfortunately, the inclusion of many additional \"reliefs\" will have a detrimental effect on the competitive position of many companies well advanced in sustainability transition, on comparability and reliability of the reports and on the transparency needed to achieve the objectives of the EU Green Deal. Any additional reliefs, if introduced, should be only temporary, i.e. for the first year, two years or three years of application of ESRS in a particular company. Introduction of permanent reliefs contradicts the very nature of mandatory reporting standards. If a provision is too difficult for undertakings to comply with at all times, it should be deleted from the standards. If a provision may be difficult for first time adopters, a temporary relief should be introduced. The relief \"undue cost or effort\" should be applicable only for the DMA process. The rationale is presented in our answer to the following question. Regarding difficulties related to collecting data from the value chain, the general 3-year relief for presenting information on metrics related to value chain is sufficient."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","This relief should not be applicable at all for metrics related to own operations. The current draft ESRS 1 provision allows companies to hide inconvenient information, for example on their gender pay gap or high number of accidents, only due to the reason that it was difficult to collect all information from own operations. That provision will not be used by the majority of companies that fairly present their situation, it will only be abused by a small portion of companies. As a result, the provision profits only companies that are trying to hide some information. Additionally, introduction of the undue cost or effort in relation to metrics related to own operations will have a detrimental effect on comparability of information disclosed in reports by all companies and by companies in particular sectors. Lack of comparability of reports will be detrimental to the goals of the EU Savings and Investments Union."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We prefer Option 1, as it is more closely aligned with IFRS. We strongly oppose Option 2. If it was to be adopted, European undertakings would be in a disadvantaged position in relation to companies from other jurisdictions that adopt IFRS standards. Financial institutions will anyway need quantitative information on anticipated financial effects from non-financial companies to assess risk related to credits and investments. Even if these information is not mandated by ESRS, companies will have to provide them. At the same time we acknowledge that less experienced companies and first time adopters may face difficulties in quantifying anticipated financial effects. This should be addressed with two solutions: (1) A three-year transition period should be granted for mandatory disclosure of quantitative anticipated financial effects (according to SBM-3 and E1-11); in the transition period undertakings shall report qualitative anticipated financial effects. (2) EFRAG should develop, on it's own or as a response to a mandate from the European Commission, a uniform methodology to quantify anticipated financial effects. Development of this methodology should be prepared and field-tested in no more of 1.5-2 years, leaving companies another 1-1.5 years to apply it before the end of the transition period. The methodology should be accompanied by appropriate tools facilitating it's application."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We see no rationale reason why financial institutions should be exempted from disclosing climate absolute GHG emission reduction targets. It is a purely sectoral issue and it should not be addressed in sector-agnostic standards. We are of the opinion that sector standards should be maintained in the ESRS infrastructure, as they would be helpful for undertakings preparing their sustainability statements. In case sector standards are not developed, sector guidance should be developed and it should address any difficulties financial institutions may face disclosing their absolute GHG emission reduction targets."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","The reference to the ILO Minimum Wage Fixing Convention No.131. is a great starting point and a leap forward in comparison to the original ESRS, however the market expectation is to be provided with the precise methodology. The convention incorporates the basic elements that should be included in the calculation. The regulator should further reference the methodology built upon the convention such as the Anker Methodology of the Global Living Wage Coalition. This would improve the comparability of the data published."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","The proposed changes may further align numerous disclosures on the due diligence process which would significantly declutter the reports. Furthermore closer alignment with SDR PAI and the OECD MNE Guidelines would improve structure of the disclosures which in turn would improve comparability of the published data."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","We disagree with deletion of the guidance related to setting targets on biodiversity and ecosystems. The guidance should be brought back to the AR and aligned with SBTN."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","Unadjusted gender pay gap is a metric that very rarely presents the actual situation in an undertaking in a fair way. The employment structure and the sector of the company often drive high level of unadjusted gender pay gap. We propose that the company is required to disclose, on a mandatory basis, unadjusted or adjusted gender pay gap; in case the company chooses adjusted gender pay gap, it should be required to disclose the methodology applied. This construction of the disclosure requirement would add no additional datapoints while allowing companies to explain the actual structure and reasons for differences in remuneration for men and women."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","There are several inconsistencies in the Glossary regarding definitions of Circular Economy terms.  Definition of \"resource inflows\" mentions \"virgin and secondary raw materials\", whereas \"virgin materials\" are not defined.  Definition of \"Key materials\" states that they \"can be sourced 'as is'\", whereas it should be consistent with definition of \"resource inflows\". Therefore phrase \"sourced 'as is'\" should be replaced with phrase \"raw materials\".  Definition of \"Raw materials\" should include \"virgin and secondary raw materials\", as this term is mentioned in \"resource inflows\" definition. It should be also explained whether \"virgin materials\" is the same as \"primary materials\".  Definition of \"Secondary resources\" does not mention \"recycling\" neither explain directly, that \"recycling materials\" belong to that group of materials, whereas ESRS E5-5 par.17 d) requires to disclose the rate of \"recycled materials used\".  Definition of \"biological materials\" does not explain whether materials of that kind are limited to virgin/primary resources/materials only, or does this group include processed materials (e.g. plywood or chipboard) Although \"technical materials\" are mentioned in ESRS E5-4 AR 2 for par. 15 a), they are not defined. Glossary defines \"Circular material use rate\" whereas this term does not exist in ESRS E5. Glossary defines \"dismantling\" whereas this term does not exist in ESRS E5."]
["Survey","MATERIALITY","Consultant (including software vendor)","Poland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We support the overall simplification of ESRS, especially with regards to language, structure of the standards and reduction of the number of datapoints. Further facilitation of the use of standards is possible. We propose EFRAG develops an XBRL tagging tool for revised ESRS, similar to the one that was developed for the VSME. This tool would provide a significant cost reduction for report preparers. We also advise EFRAG to be very cautious in relation to any additional reliefs added to the standards. As a general rule, all reliefs should be temporary only. Permanent reliefs are systemically incorrect, as they undermine coherence of the standards. We would also kindly ask EFRAG to communicate to the Commission that the European system of sustainability reporting is missing one final element: an EU-wide, uniform sustainability reporting assurance standard. It is urgently needed, and it should be developed and issued at the same time as the revised ESRS in the Delegated Act. Lack of an assurance standard issued by the Commission contributes to increase in costs for companies and non-consistent assurance practice across Member States."]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E3","there needs to be more recognition of ESRS E1 and interaction with ESRS E3"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","I do not think that this should apply to ESRS E4"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GWF Ltd","Consultant (including software vendor)","Switzerland","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We welcome the new structure without redundancies and the alignment with ISSB, which enhances comparability. In our view, these amendments, together with the other changes in the amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting and to promote better connectivity with corporate reporting as a whole.\""]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I agree","We do not agree with the significant reduction of S1 and S2 data points, as we believe insufficient importance is given to social matters."]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","22.S2","Comments on deleted datapoints in ESRS S2","I agree","We do not agree with the significant reduction of S1 and S2 data points, as we believe insufficient importance is given to social matters."]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We do not support an exception for financial institutions regarding the disclosure of absolute GHG emissions targets. While we acknowledge that estimating absolute emissions for banks, insurers, and asset managers involves complexity, such challenges are common across all sectors. Both intensity and absolute targets are necessary to provide a complete understanding of an undertaking's climate impact. Intensity targets capture efficiency but may mask rising total emissions, whereas absolute targets show the overall impact. Granting an exception only for financial institutions would also create an unlevel playing field compared to other sectors."]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome the proposal that climate-related risks, scenario analysis, and climate resilience are addressed through two separate disclosure requirements, as this approach enhances clarity and ensures more comprehensive reporting on  climate change transition and adaptation."]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We support the proposal to include biodiversity transition plans. Biodiversity deserves greater emphasis, as it is closely interconnected with climate change, and addressing it in this way represents the correct and integrated approach."]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fokus Zukunft GmbH & Co KG","Consultant (including software vendor)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","- Overall, we welcome and support the simplifications contained in the drafts, in particular the fact that materiality is used as a filter, the \"undue cost or effort\" approach, that the ESRS 1 App. A is a \"non-binding guidance\" and the clarification that sustainability reporting is based on the consolidated financial statements (financial control approach) - ESRS 1 para. 16 et seq. (fair presentation):  It should be clarified here that the sustainability report is part of the management report and that the same principles apply as in the management report - ESRS 1 para. 21 b): The reporting should be geared exclusively to the decision-making usefulness of the \"primary users\". However, the current proposal in no. 21 b) will foreseeably lead to an expansion of the information provided, as this user group must also be pleased. Point 21 b) is therefore to be deleted (see also Bullet above). - ESRS 1 para. 59: last half-sentence is to be deleted in order to preserve equality of financial and non-financial statements, consequently only the first sub-sentence in para. 4a in ESRS 2 must be retained - ESRS 1 para. 118: requirements for the possibility of referencing are to be examined, as they are currently impracticable - ESRS 2 para. 7: para. is to be deleted"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","- We welcome the concept of \"big vs. net\" in principle, this in the form of guidelines. However, industry-specific regulations must always take precedence (e.g. CRR and EBA-GL for banks or national regulations for smaller banks)."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","- Executive summary is superfluous, unauditable, only causes more costs and is a foreign body in the annual financial statements and management report"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","- In principle, the revision is to be welcomed. However, GOV, SBM and IRO should be simplified even further. - In addition, companies that have already reported under ESRS should be able to transition from the \"old\" disclosure requirements to the new ones."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","- see also Commentary on the \"Value Chain\" - ESRS 1 AR 6 at no. 30 b): this requirement is to be deleted, otherwise materiality will always be triggered"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We support EFRAG's view that NMIG will not become part of the delegated act. However, the ESRS should once again explicitly clarify that the document is only an exemplary procedure and that preparers can also choose other approaches. It is not a requirement that a company or an auditor has to take into account or fear consequences if it is not observed."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We understand EFRAG's entry into account that the requirements of the SFDR must be taken into account in the ESRS. However, the SFDR is also in urgent need of revision in this context. Relying on requirements there cannot be the solution. The EU Commission should therefore be informed that the SFDR should also be critically examined and revised within the framework of Omnibus."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The principle is to be welcomed. However, this must not lead to companies having to purchase data (see ESRS 1 para. 62), but this principle must be observed. There must be no obligation to buy data!"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","The expected financial effects are likely to be difficult to quantify for many companies at this point in time. Therefore, companies should be given the freedom to start with a qualitative assessment. ESRS 1 AR 15 b) is to be adapted accordingly."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","In principle, it makes sense to provide information on the expected financial effects, but one should not make detailed requirements here, but could, for example, provide examples of topics to be reported via NMIG. The required information should therefore be made available in a stakeholder-oriented manner (e.g. according to the needs of the value chain partners, esp. banks and insurance companies, in the case of capital market-oriented companies in addition to the capital market)."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","National commercial law must be treated on an equal footing with IFRS!"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We very much welcome the deletion of voluntary information and the reduction of the \"shall disclose\" datapoints. However, the conversion of previously voluntary data points into now mandatory data points must be rejected. It should not go beyond the \"shall\" information enshrined in the current ESRS. These should be the upper limit."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.E5.","Comments on deleted datapoints in ESRS E5","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","22.G1","Comments on deleted datapoints in ESRS G1","I partially agree and partially disagree","see ESRS 2 comment"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","see comment under no. 22)"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","- ESRS 1 Appendix A should definitely be simplified. The resolution of the 3rd level (sub-subtopics) is to be welcomed. However, it does not help if the former sub-subtopics (in brackets) are then moved to the 2nd level (e.g. S1). There is still a need for further deletion here. - on \"fair presentation\" see comment under no. 11)"]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree","See comment under no.  17.) In addition, not all companies subject to reporting obligations are covered by the SFDR."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","A binding obligation must be rejected. Developments should be monitored further before a commitment is required."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","Point 33 a) in G 1-6 should be reinserted, as this is also explicitly required in the CSRD. This point is intended in particular to protect SMEs."]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","DGRV – Deutscher Genossenschafts- und Raiffeisenverband e. V.","Business association (other than association of financial institution)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"- explicit negative statements, e.g. if no strategies or measures have been taken, could be deleted, as this is already clear from the context - clarification that \"entity specific topics\" can only affect outstanding IROs - ESRS 1 para. 64: the value chain should be limited to Tier 1 for banks."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The abovementioned 8 points have not really simplified things, save point 7 which removes a few sub-topics. The rest just seems clarifications on topics which weren't too vague in the first place.  All in all, these amendments don't really make a difference."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","Yes, this makes it more clear. There have been many arguments how to deal with mitigating actions and these additions clear this up."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","Might give some clarity/new possibilities but not a whole lot."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","There are probably simplifications made but it still seems fairly complex when trying to read it."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Seems to be an improvement given the changes listed. However, the division in DR and AR created a need to consider instructions from different sections in the standard for the same disclosure. Splitting AR in a \"may\" and a \"shall\" part below the DR run the risk of creating three sections to consider for the same disclosure. The most pragmatic and practical structure for preparers, would be to merge DR and AR completely so everything relevant for one disclosure was available in the same place with clear information on whether it is \"shall\", \"should\" or may\"."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","It is nice that this information is supplied separately. Makes the EFRAG itself clearer."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","The problematic special reporting around joint operations/ventures for E1 is made voluntary and moved to NMIG. This is a decision we welcome."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","This gives us some flexibility in reporting when data is limited. With that relief we could still report using only the data we have, even if we don't have reliable data for some parts of the business or suppliers/customers. But we would need to explain what steps we take to get better data for the future."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Regarding climate risks, it is challenging to provide quantitative figures on anticipated financial effects due to significant uncertainties, complexities, and data limitations. These risks may materialize in the future, and the analysis is based on various scenarios, each carrying substantial uncertainty. Moreover, methodologies for calculating anticipated financial effects vary between companies, depending on the approaches and assumptions applied. This variability makes disclosures difficult to compare and may result in misleading conclusions, limiting their usefulness to stakeholders. Option 2 offers a more balanced approach. It reduces the administrative burden while enhancing reporting quality. Companies would still have the flexibility to provide quantitative information where it is feasible and relevant, while also minimizing the risk of investors or stakeholders relying on non-robust data for decision-making"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","Actions in the future for physical climate risks are hard to quantify and scope will depend on scenarios and developments. Given the longer timeframe compared to other IROs this becomes particularity problematic.",null,null,""]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Vattenfall is positive to alignment between key frameworks on definitions, requirements methodologies and language. The alignment of GHG boundaries, especially with the management of joint ventures under operational control, with GHG-protocol is positive and will improve comparability across markets"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","We support the proposed reduction in mandatory and voluntary datapoints, as it meaningfully eases the reporting burden without compromising the quality of sustainability information. By removing less relevant and mainly narrative disclosures, the amendments ensure that only essential datapoints remain, striking a practical balance between efficiency and the objectives of the EU Green Deal."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Regarding amendement 10c \"whether the procurement team is involved in training related to its engagement with suppliers for the improvement of their sustainability performance\" is a bit unclear on which trainings should be reported, it is awide definition. Regarding questions 23 and para 14, the threshold for reporting is to unclear (when is case of bribery \"confirmed\"? etc)?, what is considered \"anti-corruption\" here, etc. I think reporting on convictions is enough and much clearer."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","To ensure transparency, accountability, and stakeholder trust, we encourage the inclusion of a fair representation clause in reporting practices, as it promotes balanced disclosure of both positive achievements and areas for improvement, ensures that material topics are addressed proportionally to their impact, and supports consistency, comparability, and credibility in data reporting—ultimately strengthening the integrity and usefulness of the information shared."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","No clear opinion  as we are not a financial institution."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","For reporting on pure volume of FTE & headcount it is more transparent to share all data. As long as the metrics used are aligned with the other metrics used for reporting this could be an improvement."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","It is unclear how this will align with requirements in the EU Pay transparency directive. Maybe that is why a simpler overall unadjusted pay gap is proposed. This will primarily indicate structural inequalities (e.g., underrepresentation of women in higher-paying roles), while a reporting per employee category and/or the adjusted pay gap would be more indicating any actual pay differences. But as the EU Pay transparency directive addresses more the latter, this could be a reasonable proposal."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","Only filled in what is applicable to us.   Regarding G1: The threshold for reporting is to unclear (when is case of bribery \"confirmed\"? etc)?, what is considered \"anti-corruption\" here, etc. I think reporting on convictions is enough and much clearer."]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","35.E1-7."," Do you agree with the amendments of this chapter? ","I disagree","Disclosure Requirement E1-7 - Energy consumption and mix : There should be an alignment between proposed paragraph 28 and 30, energy consumption and energy production. Important is to distinguish between fossil energy sources and fossil free energy sources. Therefore the bundling of nuclear and fossil into the category non-renewable linked to production should be broken up into \"Nuclear\" and \"Fossil\" e.g. following datapoints for consumption. We suggest that the disclosure requirement on energy production be disaggregated in the same manner as energy consumption—into renewable, fossil, and nuclear categories—to ensure consistency, enhance comparability, and provide a clearer picture of an organization's energy profile. This alignment would support more transparent reporting and better reflect the diversity of energy sources contributing to overall production.","E1","Disclosure Requirement E1-7 - Energy consumption and mix",""]
["Survey","Vattenfall","Preparer (non-financial preparing a sustainability report)","Sweden","35.E1-8."," Do you agree with the amendments of this chapter? ","I disagree","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions: On the new paragraph 33 (amended from AR 43 c, 45 e and 46 j : Due to the inherent complexity and limited availability of reliable data across the value chain, the disclosure of biogenic emissions under Scope 2 and Scope 3 should be voluntary. Mandating such reporting could lead to inconsistencies and undermine the comparability and credibility of climate disclosures.","E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","AKI","Asset manager/Investor","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","The chapter is better organised and understanable now. For further improvement it is recommended to differentiate clearer between IRO and topics in chapter 3."]
["Survey","AKI","Asset manager/Investor","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","We support the idea that incident which have occured during the reportin period should be reported as well as remediation efforts."]
["Survey","AKI","Asset manager/Investor","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","AKI","Asset manager/Investor","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","I agree, however we would wellcome site specific information on biodiversity as well as mentioning metrics in ESRS 2 for social topoics. Companies alrady report usefull social metrics and these should be included here."]
["Survey","AKI","Asset manager/Investor","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Requireing examples in disclosures would be helpfull and illustrative"]
["Survey","AKI","Asset manager/Investor","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The combination of allowing to omit reporting because of \"undue cost and effort and lack of data quality\" is problematic and might lead to the a lack of crucial data for investors. We are also highly concerned about the reduction of data points for non employees. This is the most vulnerable group of workers and at the same time related to social risks which the investor needs to know. In particular we need to know about H&S risks of this group and about their contracts and wages. This group is also at risk of forced labour. So ommitting reporting on them might be in conflict with the foced labour disclosure requirement f. ex in the UK."]
["Survey","AKI","Asset manager/Investor","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","These combined reliefs are going to far and endanger a level playing field for companies."]
["Survey","AKI","Asset manager/Investor","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","It is important to estimate financial effects. This data is needed  to integrate sustainability into the business strategy."]
["Survey","AKI","Asset manager/Investor","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","AKI","Asset manager/Investor","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","It must made sure that the coherence with IFRS is given. Reporting below IFRS should nt happen"]
["Survey","AKI","Asset manager/Investor","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","AKI","Asset manager/Investor","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","AKI","Asset manager/Investor","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","AKI","Asset manager/Investor","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The change seems reasonable"]
["Survey","AKI","Asset manager/Investor","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The new rule treats workeres in the EU differnt from workers outside of the EU as a wage below the living wage would become acceptabel for them. The ILO requirements for wage setting are not an adequate safeguards to prevent this."]
["Survey","AKI","Asset manager/Investor","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","I very much wellcome this change. It makes it much easier for investors to understand PAI 10 and 11. I very much hope that present inconsistencies in the reporting on these PAI are solved by this change."]
["Survey","AKI","Asset manager/Investor","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","It reamins to be seen how data on biodiversity evolves. This ist a good staring point."]
["Survey","AKI","Asset manager/Investor","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","AKI","Asset manager/Investor","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Danish 92 Group","NGO","Denmark","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Positively, the Exposure Draft maintains key elements of the ESRS that are critical to ensure alignment with the international standards on responsible business conduct. Importantly, the draft maintains:  1. The double materiality approach and a definition of impact materiality and scope of reporting that covers impacts across own operations and the full value chain - as far as consumers are concerned. This is in alignment with international standards on responsible business conduct (UN and OECD). 2. Emphasis and synergy with the concept of sustainability due diligence by highlighting how such efforts should inform companies' double materiality assessments whilst drawing on its main features in cross-cutting and topical disclosure requirements around companies' sustainability policies, actions, metrics and targets. 3. Emphasis on engaging with stakeholders, including affected rightsholders and their representatives, to inform the double materiality assessment and in companies' sustainability impact management and related disclosures. 4. The sustainability structure of the affected stakeholder groups: workers, workers in the value chain, affected communities, indigenous peoples, and consumers/end-users underpinned by sustainability sub-topics that substantially capture topics commonly at risk for these groups.  It is of utmost importance that these positive elements of the Draft exposure are maintained!  Negatively, however, we are concerned that the simplification will jeopardize the robustness and original purpose of the DMA. The lack of detail, concrete information and comparable and usefull data that can be obtained is a problem for both NGOs and investors."]
["Survey","Danish 92 Group","NGO","Denmark","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","It is usefull that chapter 3 addresses the question of how prevention, mitigation and remedy of impacts shall be considered in materiality assesment, but if the DMA lacks specificity, the result will also be insufficient."]
["Survey","Danish 92 Group","NGO","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","While acknowledging the need for flexibility, we are concerned that reporting will lack clarity, sufficient detail and deliver comparable data."]
["Survey","Danish 92 Group","NGO","Denmark","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","While understanding the need for simplification, we are concerned that the (so far) 68% reduction of data points is problematic for the purpose of generating  relevant and comparable information. It is of the utmost importance that the number of data points is not reduced further. Any further reduction of the standards or dilution of its key concepts would be highly problematic.  In achieving this big a reduction many of the previous explanations, examples and guidance elements have been lost. We therefore highlight the importance of ensuring that guidance around implementation is given utmost priority in the next phases to avoid under-implementation and support companies in implementing the standard in its new form.  In the follwing two specific points of critical concern, we agree with the response from Frank Bold, in: 1. The original Disclosure Requirement in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. We welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened. 2. We strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics and the anticipated sectoral standards which would have provided such metrics will not be adopted, shift the expectations for disclosure of metrics for S topics to entity-specific disclosures."]
["Survey","Danish 92 Group","NGO","Denmark","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","In agreement with Frank Bold, we support the proposed changes. We agree with the removal of the confusing 'may disclose' elements. However, where they provide useful examples of disclosures, they could be included directly in the standards as \"examples\". This is particularly the case for the topics for which the reporting practice is evolving, such as Biodiversity and Ecosystems."]
["Survey","Danish 92 Group","NGO","Denmark","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The ESRS  are not clear concerning the combined effects of the reliefs and how the reliefs should interact. Interpreting and applying these reliefs independently of each other makes it possible to abuse and omit important information, resulting in significant differences in reporting practice."]
["Survey","Danish 92 Group","NGO","Denmark","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","We do not agree that the combined reliefs give an acceptable balance. They should clearly require the undertaking to improve the coverage and quality of the data needed to meet ESRS requirements."]
["Survey","Danish 92 Group","NGO","Denmark","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","In general, we find it to be essential to focus on the integration of all elements of sustainability into companies' business strategy, considerations and risk management. Resigning on this ambition is counterproductive to the objective of putting sustainability reporting on the same level as financial reporting."]
["Survey","Danish 92 Group","NGO","Denmark","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","While acknowledging the need for simplification, we remain concerned about the right balance between reporting effort and users' needs.",null,null,""]
["Survey","Danish 92 Group","NGO","Denmark","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Reliefs must be IFRS compliant. Any further rekiels will undermine the objective of setting a global baseline for ESG reporting.."]
["Survey","Danish 92 Group","NGO","Denmark","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Danish 92 Group","NGO","Denmark","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We generally agree with these changes."]
["Survey","Danish 92 Group","NGO","Denmark","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We generally agree with these changes."]
["Survey","Danish 92 Group","NGO","Denmark","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","The global carbon budget is defined in absolute terms. For this reason, it remains essential and the financial institutions should definately not be exempted."]
["Survey","Danish 92 Group","NGO","Denmark","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","In alignment with Shift and the DIHR, we find that it is critically important to maintain S1-9 on Adequate Wages. Workers have a human right to a living wage, meaning sufficient remuneration to support themselves and their families in a life of basic dignity. The methodology requires companies to compare actual wages to an \"adequate wage\" standard for their employees in the EU while directing them to compare with legal minimum wages for their employees outside the EU if those minimum wages are agreed in line with the ILO's wage-setting principles. 1. It undermines the objective: the methodology for reporting on whether all employees earn an adequate wage should not include an option that is tied to the generally much lower standard of the legal minimum wage 2. It is discriminatory. The legal minimum wage nearly everywhere remains substantially below a living wage threshold. The disclosure would have companies apply a lower standard to their employees outside of the EU than they apply to those inside the EU. 3. It undermines comparability of reports: Companies have very different proportions of their workforce inside and outside the EU. If they apply these different standards for reporting on adequate wages depending on the location of employees, the data is not comparable. This undermines the disclosure's utility for investors and other stakeholders that use sustainability reports."]
["Survey","Danish 92 Group","NGO","Denmark","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","In line with Frank Bold, we agree that measurable targets related to biodiversity and ecosystems shall be set and disclosed according to the guidance and examples given by relevant global frameworks, such as SBTN (Step 3 - Measure, Set & Disclose Targets), TNFD (component P1 and P2 & Annex 5, sector guidance and guidance on Target Setting) & resources by World Economic Forum Nature-Positive Transitions."]
["Survey","Danish 92 Group","NGO","Denmark","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","Gender pay gap should be seen as a general concern for all companies across sectors and should be addressed as such."]
["Survey","Danish 92 Group","NGO","Denmark","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"In alignment with WWF, we emphasize that the 1.5°C alignment shall remain the central and non-negotiable reference for corporate climate targets. Allowing companies to refer alternatively to the EU Climate Law risks undermining scientific robustness and integrity, as it could open the door to selective interpretations and policy developments."]
["Survey","NBIM","Asset manager/Investor","Norway","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We note that EFRAG has made progress in this area. The amended ESRS now apply a materiality filter to all reported information, aligning with ISSB's approach. The fair presentation framework advances this alignment further, particularly for the financial materiality component of ESRS double materiality assessment. We welcome these changes as they shift focus from strict compliance to disclosure of more decision-useful information for investors. We particularly value EFRAG's permanent reference to IFRS Industry Based Guidance (including IFRS S2 and SASB Standards) for entity-specific disclosures. To enhance interoperability further, we recommend explicitly incorporating SASB standards into the ESRS Double Materiality Assessment process. SASB standards are specifically designed to identify financially material sustainability topics by industry, which would provide structured guidance for companies as they determine which sustainability issues affect their financial performance."]
["Survey","NBIM","Asset manager/Investor","Norway","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","NBIM","Asset manager/Investor","Norway","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","In our previous feedback, we identified how the original ESRS structure created reporting inefficiencies. EFRAG has now streamlined this approach by allowing companies to report core information once rather than repeating similar details across multiple sections.  We welcome this change, as it improves clarity, reduces repetition, and results in more effective application of the standards by companies."]
["Survey","NBIM","Asset manager/Investor","Norway","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We note that EFRAG has made progress in this area. We support the reorganization that clearly separates mandatory from non-mandatory requirements, and eliminates \"may disclose\" provisions, as it makes the application of the standards more effective. However, we do believe terminology, metrics and reliefs of ESRS can be further aligned with ISSB which will make it easier for companies to comply with multiple reporting frameworks. For example, further terminology alignment opportunities include scenario analysis disclosures in ESRS E1 (Climate Change) and resilience assessment disclosures in ESRS 2 Strategy, Business Model and Management (SBM-3).  Additionally, with the removal of specific biodiversity metrics from the mandatory text of ESRS E4 (Biodiversity and Ecosystems), we recommend incorporating an explicit reference to the TNFD core global disclosure metrics in the mandatory text itself. While the Non-Mandatory Implementation Guidance mentions TNFD as a framework companies \"might consider\", reference in the mandatory text would establish a clear measurement standard, ensure comparable reporting, and align with emerging global standards."]
["Survey","NBIM","Asset manager/Investor","Norway","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","EFRAG has proposed several new relief provisions that diverge from ISSB standards. These create interoperability challenges. When combined with the enhanced materiality filter introduced in the amended ESRS, these reliefs also increase the risk of material information gaps in sustainability reporting. For example, the extension of \"undue cost or effort\" relief to all metrics, even those for a company's own operations, is concerning. Companies can use this relief to omit important sustainability metrics. Similarly, the \"relief for acquisitions and disposals\" creates differences in reporting boundaries compared to financial statements, undermining the connectivity between sustainability and financial reporting. What requires careful consideration is the lack of clarity on how these reliefs can be used or how they might interact with each other. This can potentially create a patchwork of inconsistent disclosures across companies and sectors. They further increase the complexity of the application of standards. We recommend aligning relief provisions with ISSB standards to ensure consistent application regardless of reporting framework. Furthermore, EFRAG should review which relief provisions should be transitional and which should be permanent, based on the final scope of Corporate Sustainability Reporting Directive (CSRD) and as sustainability reporting practices mature."]
["Survey","NBIM","Asset manager/Investor","Norway","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","As investors, we require financial effects disclosures to evaluate how sustainability factors impact financial position and performance. Quantitative data enables precise assessment of financial implications and facilitates meaningful comparison across companies. While qualitative explanations provide valuable context, they simply cannot replace the numerical information that forms the foundation of valuation methodologies and investment decisions. However, we recommend adopting this option with all ISSB relief mechanisms to achieve full interoperability. This would include incorporating ISSB's skills and capabilities limitation provision, which would help companies during the implementation phase. Furthermore, mandating Option 1 aligns with the global direction of sustainability reporting, as ISSB standards are now being implemented worldwide. Making quantitative disclosure optional would not only create gaps in the reporting landscape but would also hamper our ability to conduct consistent cross-border portfolio analysis. We acknowledge the methodological challenges companies face when calculating these financial effects. However, reporting capabilities and methodologies will mature as ISSB and ESRS standards become more widely adopted. Rather than reducing requirements, we recommend that EFRAG references ISSB's educational guidance to support companies through this transition. For these reasons, we have reservations about Option 2, which would make quantitative disclosure permanently voluntary. If adopted, it would substantially diminish the transparency, comparability, and overall usefulness of sustainability reporting for investment decision-making."]
["Survey","NBIM","Asset manager/Investor","Norway","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We welcome interoperability improvements with ISSB standards, but remain concerned about several amendments that reduce alignment between frameworks. These changes compromise comparability and diminish the quality of information available to investors. The proposal to make quantitative disclosure of anticipated financial effects optional diverges from ISSB's approach (as detailed in our response to question 19). Further, limiting financial effects disclosure to \"already announced\" investments and plans departs from ISSB's comprehensive framework and undermines the essential connectivity between sustainability impacts and financial statements. Investors require a complete picture of how sustainability issues affect business performance and prospects. It's notable that none of the 35+ jurisdictions adopting ISSB standards are moving away from this disclosure requirement. Instead of reducing requirements, implementing capacity building initiatives and adopting ISSB-aligned relief mechanisms would better address preparers' challenges. The hybrid approach to GHG emissions boundaries also introduces inconsistencies. By requiring financial control as default while mandating operational control reporting in certain circumstances, EFRAG creates a system where identical operations could show different emissions profiles under ESRS versus ISSB frameworks. This approach would require companies to maintain dual calculation methodologies and would invite inconsistent implementation as preparers make varying judgments about when financial control fails to provide \"fair presentation.\" Additionally, the introduction of other relief provisions that diverge from ISSB standards (detailed in our response to question 17) further weakens interoperability. The European Commission explicitly mandates maximizing interoperability with global standards. In this context, EFRAG's threshold for creating further divergence should be high. We believe EFRAG can achieve simplification and burden reduction without compromising alignment with ISSB. Full alignment would ultimately reduce reporting complexity while advancing a unified global sustainability reporting infrastructure that benefits both preparers and users."]
["Survey","NBIM","Asset manager/Investor","Norway","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","NBIM","Asset manager/Investor","Norway","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","We are concerned that EFRAG has proposed deletion of seven ISSB-aligned disclosure requirements.  This contradicts the European Commission's direction to enhance interoperability with global standards. While datapoint reduction is important for simplification, the threshold for removing globally aligned datapoints should be high. Preserving these datapoints would better serve both European companies seeking reporting efficiency and international investors requiring consistent information. These include: •\tESRS 2 General disclosures GOV-1: Information about management's role in governance processes for monitoring and overseeing impacts, risks and opportunities (aligned with IFRS S1, para. 8 (22 c))  •\tESRS 2 General disclosures - MDR for actions and resources in relation to material topics: Disclosure on monitoring progress made against previously disclosed actions, including quantitative and qualitative information (aligned with IFRS S1 para 38)  •\t •\tESRS 2 General disclosures- IRO-1, paragraph 53(e): Disclosure on the extent to which and how the process to assess and manage material sustainability impacts, risks and opportunities is integrated into the undertaking's overall risk management process (aligned with IFRS S1 paragraph 25(b))  •\tESRS E1 Climate change (53 amended): Disclosure of gross GHG emissions intensity per unit of products and/or services (aligned with IFRS S2 paragraph 33)  •\tESRS 2 General disclosures GOV-2: Description of whether and how climate-related considerations are factored into executive remuneration (aligned with IFRS S1 par. 10 (29 c))  •\tESRS 2 General disclosures GOV-2: Disclosure of the percentage of executive management remuneration recognized in the current period that is linked to climate-related considerations (aligned with IFRS S1 par. 10 (29 c))"]
["Survey","NBIM","Asset manager/Investor","Norway","22.E1.","Comments on deleted datapoints in ESRS E1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","These deleted points also include: •\tESRS E1 Climate change (53 amended): Disclosure of gross GHG emissions intensity per unit of products and/or services (aligned with IFRS S2 paragraph 33)  •\tESRS E1 Climate change AR 46(g) amended: Information on the extent to which Scope 3 greenhouse gas emissions are measured using inputs from specific activities within the entity's value chain (primary data), secondary data or a combination of both (aligned with IFRS S2 paragraph B32)"]
["Survey","NBIM","Asset manager/Investor","Norway","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The new requirement to disaggregate metrics for the top 10 largest countries by employee headcount (with more than 50 employees) provides better geographic visibility. This change should enhance transparency regarding workforce conditions across different jurisdictions, and support more effective assessment of risks and opportunities."]
["Survey","NBIM","Asset manager/Investor","Norway","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We support the provision of guidance on what biodiversity and ecosystems-related targets can cover. This should refer to Taskforce on Nature-related Financial Disclosures (TNFD) where possible."]
["Survey","NBIM","Asset manager/Investor","Norway","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","The deletion of the voluntary datapoint on adjusted gender pay gap by employee category removes important contextual information for investors. While the unadjusted global pay gap provides an overall indicator, it alone does not provide sufficient insight into whether pay differences stem from legitimate factors (such as role distribution, experience levels, and qualification differences) or from potential discrimination. The adjusted metric, which accounts for these factors, offers complementary information that helps us evaluate whether companies are addressing structural inequalities in addition to direct pay discrimination."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The Danish Government welcomes the simplified approach to the DMA especially regarding part 3,5 about practical considerations. It's important that the DMA remains dual. Yet the process itself has not been simplified or reduced in scope. We are therefore concerned that these changes may not achieve a sufficient alleviation of reporting burdens. The DMA should be more sector-oriented. Also, further improvements and clarifications are needed:  It should be clarified, that although it's expected that the top-down and the bottom-up approaches have the same results, this should not be understood as a compliance tool to assess whether the DMA results are correct.  ESRS-1 para-29 states that the undertaking shall update the conclusions of its DMA from previous years to exclude information that's no longer material or include information that has become material. It's unclear how an undertaking is expected to assess this without conducting the full DMA process again as described in Basis for Conclusion paragraph-172. Further clarification is needed.  Although not part of the DMA chapter itself we find that, the amendment to Chapter 2 of ESRS-1 and Appendix B about the core principles underlying 'fair presentation', that the explicit application clarifies the use of this concept.  It's however paramount that this concept and its correlation to similar concepts in other legislative frameworks and standards is explained in detail, especially considering the introduction of the possibility of including non-material information. We refer to our answer to question 25.  We also encourage EFRAG to clarify how much entity-specific information to include in the context of the requirements related to the DMA and the concept of \"fair presentation\"  Regarding ESRS-1, para-107, point (ii) allowing the inclusion of non-material information, we encourage EFRAG to further clarify and emphasize the conditions that needs to be met specified in para-107 a and b."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","We welcome the additional guidance on how to consider remediation, mitigation and prevention which was much needed. However, we find that the right balance has not been reached completely. The examples in Appendix C to ESRS 1 are difficult to read and understand and we find that reading through the examples only in very few cases the net-approach are used. We acknowledge the point on health and safety impacts specifically but fear a general emphasis on gross risks that are not material in practice. We appreciate EFRAG's further consideration in this balance in a field test.  In Appendix C, the example where an impact occurred in the reporting period and a remediation action has been taken, is fully completed and the impact is remediated seems to be in conflict with ESRS 1 para 36 that states that the undertakings positive impacts should be considered in their own right and shall not be netted off against its negative impacts.  Also, sector guidance is especially called for in the market. Therefore, the Danish government believes that sector-specific guidance can support and limit the double materiality assessment in such a way, that the reporting is focused and useful, especially for the financial sector. In this way, it is possible both to reduce the burden on reporting companies, as their double materiality assessment becomes less extensive and more sector-oriented, and to make the reporting more decision-useful."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","The added flexibility is welcomed, especially the possibility to use appendices. Clarification as to whether an appendix to the sustainability statement should be placed in conclusion of the sustainability statement or if it could be placed at the end of the annual report or elsewhere (e.g. with incorporation by reference) would be appreciated  As we understand ESRS 2 para 31 it allows the undertaking to arrange its disclosures in a way that reflects its management priorities and business model. We support and recommend further flexibility by changing the requirement in ESRS 1 para 105 that states that the sustainability statement shall be structured in four parts in the order: general, environmental, social and governance-information. The order of the main chapters in the statement should be up to the reporting entity, so that they can structure the chapters in order of relevance. See also our answer to question 33."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We agree with the proposed amendments and welcome the simplification of the minimum disclosure requirements, which were both difficult to understand and to navigate.  The reduction in 'shall'-datapoints for PAT's is appreciated and will lead to more relevant disclosures and be less prescriptive, which will enhance comparability. That said, The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration.  We find that moving description of IRO's to IRO-2 is an improvement on the previous setup. Several Danish \"wave-1\" companies have argued that the previous IRO-2 disclosure requirement had little to no value."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We welcome the amendments to achieve clarity and accessibility, especially the decision by EFRAG to completely remove the 'may disclose' datapoints and the positioning of ARs in immediate conjunction with relevant DRs which eases readability of the standards."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We welcome the proposed reliefs and the increased interoperability with ISSB especially regarding the introduction of the relief from undue cost and effort. However, we find that the terminology introduced in ESRS-1, para-45 a and para-47 regarding reasonable and supportable information vs. evidence needs clarification and we encourage EFRAG to explicitly point to the reasoning behind the terminology and connection with ISSB.  Also, we find that ESRS-1 para-67 and AR 28 for para-67 are difficult to understand due to the fact that para-67 on the one hand states that it's not needed for undertakings to collect data from their value chain in relation to metrics, and explicitly gives scope-3 emissions as an example of this and on the other hand in AR 28 for para-67 states that - with the exception of scope-3 - metrics in topical ESRS do not require the inclusion of upstream and downstream data.  To complicate it further, ESRS-1 para-91 states, that scope-3 emissions are excluded from the relief introduced in the paragraph to comply with disclosure requirements when only having reliable data for part of the scope or value chain. This can in our understanding imply, that if an undertaking only can collect reliable data for parts of the value chain for its scope-3 emissions, it's not allowed to disclose solely on this part of the value chain and disclose the actions taken to increase coverage and quality, but the undertaking is allowed to disclose its scope-3 emissions based on estimates alone. Please also refer to our answer to question 18 below.  We therefore ask EFRAG to clarify these disclosure requirements and their interaction.  Furthermore, we bring to the attention of EFRAG that the reference in ESRS-1 para-91 to ESRS E1-6 GHG-Emissions should be updated to ESRS E1-8 GHG-Emissions."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We welcome  the intended relief  in ESRS 1 para 91 that allows an undertaking to  report metrics with a partial scope  of calculation, however there are several aspects that we do not find  sufficiently described and thus hard  to interpret, for instance how ESRS 1 para 91 should be understood in conjunction with ESRS 1 para 67 and AR 28 for Para 67 – see our answer to question 17 above.  In addition to the concerns described in question 17 above, we believe that it is not sufficiently clear if this relief for metrics is only applicable to impact-metrics or if this is also applicable to metrics for risks and opportunities.  We would also like to raise a concern that when requiring the undertaking to disclose the actions taken to improve future quality and coverage and at subsequent reporting dates whether reliable data has become available, this could indicate that the relief is only temporary until the actions taken has resulted in the availability of data in high quality and coverage. The paragraph does not take into account the situation, where the undertaking does not have the ability to take any actions (e.g. because it does not have any buying power over its supplier) and where there is no prospect that reliable data will become available in the future."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We find that option 1 is the best solution as this allows for the highest level of interoperability to IFRS. Interoperability with IFRS is particularly important, as the reduced scope of the CSRD means that the majority of companies covered by the CSRD will also be subject to IFRS."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","The Danish Government supports the amendments to ESRS 1, requiring companies to apply key qualitative characteristics when preparing sustainability statements, making the concept of 'fair presentation' more explicit. This enhances consistency and understanding across different standards. However, differences in interpretation between preparers and auditors already exist. EFRAG must therefore clearly explain how 'fair presentation' in IFRS and similar concepts in the Accounting Directive relate, to ensure consistent understanding and reduce disagreements.  We find that interoperability across various legislative frameworks and standards are essential, we therefore welcome EFRAGs work to further streamline the ESRS standards in this regard. The amendment to the disclosures in ESRS E1 GHG emissions and the implementation of IFRS reliefs on undue cost and effort is especially welcomed as well as the streamlining of the language used in ESRS and IFRS. Where differences in meaning or terminology remain, these should be explicitly explained in the ESRS."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.E5.","Comments on deleted datapoints in ESRS E5","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","22.G1","Comments on deleted datapoints in ESRS G1","I partially agree and partially disagree","The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","The Danish Government welcomes the amendment to Chapter 2 of ESRS 1 and Appendix B, which require undertakings to apply the fundamental and enhancing qualitative characteristics of information when preparing their sustainability statements. These characteristics are the core principles underlying 'fair presentation', and their explicit application clarifies the use of this concept.  Making the concept of 'fair presentation' more explicit within the ESRS is valuable, as re-using established principles across multiple legislative frameworks and standards enhances interoperability and better facilitate understanding. Clarifying its application helps address potential inconsistencies that may arise when similar concepts are defined or interpreted differently.  'Fair presentation' is a well-recognized and longstanding concept that preparers, auditors, and users have applied for years in financial reporting.   However, we have already experienced differences in understanding between preparers and auditors regarding how these concepts should be interpreted. It is therefore essential that EFRAG clearly explains the coherence between 'fair presentation' in the IFRS Conceptual Framework for Financial Reporting, 'fair presentation' in IFRS S1, and the concepts of 'true and fair view' and 'fair review' as defined in the Accounting Directive. All these concepts are rooted in the same fundamental and enhancing qualitative characteristics.  Ensuring clarity on these connections will foster better understanding among all parties, resulting in more relevant reporting and a shared interpretation of key concepts, ultimately reducing disagreements between preparers and auditors."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","The Danish Financial Supervisory Authority (DFSA) does not agree that financial institutions should be exempted from disclosing values for absolute GHG emissions.   DFSA considers it important to disclose this value, as both intensity-based and absolute targets are necessary to provide a realistic and nuanced picture of an institution's progress in the area of climate action. Intensity targets alone may potentially obscure any increase in GHG emissions. Furthermore, information on an institution's total GHG emissions is one of the most central values to disclose in order to reach the objectives of the CSRD. Intensity-based and absolute targets, together with other descriptions of the institution's sustainability strategy, provide the best overall picture of the institution's climate impact as well as its efforts and contributions to the green transition.   However, DFSA would like to add that it is important to establish a definition of the value chains of financial institutions in order to strengthen the application and user quality of the disclosed values for absolute GHG emissions. The values disclosed across financial institutions should be clearly delineated, well-defined, and comparable."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","We partially agree with the way the SFDR PAI have been incorporated. The datapoints removed are either rarely used, irrelevant, provided for in other reporting, and as such we see their removal as an efficient way to reduce burdens. We are, however, unsure of the reference to ESRS E4, AR 13 regarding PAI 12, as we have been unable to find this point. We assume that the reference was meant to be AR3 – if this is the case, we can also agree with this amendment.   Concerning the datapoint on GHG intensity of a company E1-6, para 53-55 we still think that this datapoint is highly relevant for FMP when assessing whether an investee company can be perceived as a sustainable investment pursuant to article 2(17) and the requirement of doing no significant harm. In addition, we would like some clarity on whether a company is still obliged to report on GHG intensity but instead of being obliged to calculate this by use of the company's revenue, it is up to the company how to calculate the GHG intensity pursuant to the NMIG."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","In ESRS 2 para 28 (b), it is stipulated that if the undertaking concludes that climate change is not material and omits all disclosure requirements in ESRS E1 climate change, the undertaking shall disclose the basis for this conclusion. However, due to the fact that ESRS 2 is no longer mandatory, it is difficult to understand how this disclosure requirement should be understood.  The same issue arises for ESRS 2 para 30 that states that if the undertaking has not adopted policies, actions and targets, it shall disclose this fact. Due to the fact that ESRS 2 is no longer mandatory, it is difficult to understand how this disclosure requirement should be understood. This also applies to ESRS 2 para 44.  We therefore encourage EFRAG to clarify this.  ESRS 2 para 22 requires undertakings to disclose, amongst other things, how the undertaking addresses or plans to address its IROs. In AR 14 for para 22 it is further clarified that this includes a clear reference to the specific policies, actions and targets implemented during the reporting period. It is unclear if this implies that policies implemented in previous years or targets set in previous years are not to be included?  As we understand ESRS 2 para 31 it allows the undertaking to arrange its disclosures in a way that reflects its management priorities and business model. We support and recommend further flexibility by changing the requirement in ESRS 1 para 105 that states that the sustainability statement shall be structured in four parts in the order: general, environmental, social and governance-information. The order of the main chapters in the statement should be up to the reporting entity, so that they can structure the chapters in order of relevans."]
["Survey","The Danish Ministry of Industry, Business and Financial Affairs","National supervisory authority & regulator","Denmark","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Interoperability:  For improved understandability and interoperability with the voluntary standard for SME's (VSME) as well as with the proposed value chain cap, it is important that ESRS clearly explains how the disclosures are able to inform about aspects in the value chain in regard to: -\tGHG removals (E1-9) -\tMicroplastics (E2-4) -\tSubstances of very high concern (E2-5) -\tWaste (E5-5)  This is on the one hand to give clear guidance to undertakings in-scope of the CSRD as to how this should be done in line with VSME and on the other hand to protect SMEs from data requests beyond the value chain cap.   The reasoning for this is, that the VSME does not contain information about these topics and thus the undertaking in scope of CSRD could be required to request data from its value chain partners that goes beyond the value chain cap.  The Danish Government would be supportive should further feasible reductions in data points be identified and taken into consideration."]
["Survey","NABU","NGO","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Chapter 3 is presented in a clearer and more structured way. Section 3.1 improves the definition of materiality of information by replacing the criterion of \"significance\" with the \"understandability\" of impacts, offering stronger guidance and ensuring consistency with the CSRD as well as international sustainability due diligence standards. The section also explains how materiality of information connects to the (fundamental) qualitative characteristics of information described in Chapter 2, and to the requirements for aggregation and disaggregation of information (for example, paragraph 52 on avoiding \"obscuring\").  Chapter 3.3.2, paragraph 37 overlooks the fact that financial materiality assessment is intended not only to identify material information but also to determine material risks and opportunities, as mandated by the CSRD. These risks and opportunities appear only midway through paragraph 38, which disrupts the coherence of the text."]
["Survey","NABU","NGO","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","It is helpful that Chapter 3 discusses how prevention, mitigation, and remedy of impacts should be addressed in materiality assessment; however, the rules could be stated in a simpler and more accessible manner. Paragraph 34, for instance, uses unnecessarily complex language to convey the straightforward point that actual impacts must be considered as they occurred during the reporting period, and that any remediation after the fact is irrelevant.  We particularly welcome the clarification that potential impacts requiring substantial and ongoing prevention or mitigation efforts should be assessed on a gross basis. This clarification is essential, since without it companies would, in theory, be unable to report on how they manage such issues. To strengthen this guidance, it would also be valuable to link it to the materiality of information filters, which could help companies differentiate between significant efforts and routine compliance measures or standard practices."]
["Survey","NABU","NGO","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","NABU","NGO","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We welcome the elimination of duplications between the cross-cutting and topical standards and support the stronger focus on general disclosure requirements. Similarly, many PAT provisions within the topical standards functioned more as illustrative examples or guidance than as concrete datapoints, which we consider appropriate.  That said, the original disclosure requirements in the environmental standards regarding site screening in materiality assessments have been replaced with an application requirement under ESRS 2 IRO-1. This change effectively makes transparency on this issue optional. Given that consideration of local context is a fundamental component of sound materiality assessment, it should be explicitly recognised in Chapter 3 of ESRS 1. Moreover, ESRS 2 IRO-1 should include a clear datapoint requiring undertakings to report how they screened their locations and value chains.  We also appreciate the improved emphasis within the environmental standards on the importance of disaggregating disclosures. However, meaningful disaggregation can only be achieved if the screening of locations is carried out thoroughly."]
["Survey","NABU","NGO","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We support the proposed changes and agree with the removal of the \"may disclose\" elements, as their status has often caused confusion. However, it is not necessary to remove all of them from NMIG. When these elements serve as useful examples of disclosures, they could be incorporated directly into the standards as illustrative \"examples.\" This approach is particularly valuable for topics where reporting practices are still evolving, such as biodiversity and ecosystems. Including such examples within the standards would help first-time preparers understand the types of information likely to be relevant and provide a foundation for standardizing metrics. Requiring consultation of a separate document like NMIG creates an unnecessary hurdle."]
["Survey","NABU","NGO","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The standards lack clarity regarding the combined effect of the reliefs and how they are intended to interact. Applying these reliefs independently risks abuse, omission of material information, and significant inconsistencies in reporting practices.  The reporting of metrics is affected by the interplay of undue cost and effort, and lack of data quality reliefs. However, the standards do not properly contextualize these reliefs, nor do they set explicit requirements or timelines for companies to improve data coverage and quality. This issue is compounded by the relief that unconditionally allows the exclusion of joint operations. If environmental metrics related to these operations are material, the standards should encourage their eventual disclosure. The existing undue cost and effort, and lack of data quality reliefs already provide sufficient flexibility for this purpose.  There is also a lack of coherence in reliefs related to financial effects, i.e., information essential for understanding risks and the company's capacity to address them. For example, the limitation tied to announced investment plans focuses disclosure on effects that are easier to assess and quantify, while other reliefs allow companies to omit quantitative disclosures altogether.  We broadly support the relief in ESRS 1, paragraph 90, which permits exclusion of activities that are not significant drivers of the IROs when calculating metrics. However, the application of this option needs clarification for specific environmental and social metrics that are standardized in the ESRS."]
["Survey","NABU","NGO","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","The combined reliefs should explicitly require undertakings to enhance both the coverage and quality of the data needed to comply with ESRS requirements. For metrics related to the company's own operations or those directly standardized in the ESRS, this obligation should include a clear time frame. For other metrics, gradual improvements over time should also be explicitly mandated, while still allowing flexibility under the undue cost and effort relief."]
["Survey","NABU","NGO","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is essential for an undertaking to integrate sustainability into its business strategy, planning, and risk management. It is also crucial for determining financial materiality, including avoiding the overreporting of topics as financially material. Abandoning this objective would conflict with the goal of placing sustainability reporting on the same level as financial reporting, integrating both, and ultimately addressing the \"tragedy of horizons.\"  We consider Option 1 to be unnecessarily extensive and lacking a defined time frame, but broadly acceptable. We disagree with the statement that \"[d]ifferent from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources.\" The proposed ESRS already include the undue cost and effort relief, which appears to cover such situations.  Regarding Option 2, we do not find it justifiable to go beyond the IFRS relief. One of the strongest arguments from stakeholders advocating simplification of the ESRS was that, as a principle, the standards should align with IFRS unless the CSRD or other EU legislation explicitly require otherwise. Deviating from this principle risks undermining the development of a global baseline supported by both the EU and the ISSB, which is critical for establishing a level playing field for EU companies."]
["Survey","NABU","NGO","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","NABU","NGO","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Reliefs should not exceed those provided under IFRS, as going beyond would undermine the goal of establishing a global baseline for ESG reporting—an essential element for ensuring a level playing field for EU companies in a global context.  The undue cost and effort relief described in ESRS 1, paragraphs 87–89, is a comprehensive measure that addresses nearly all situations in which an undertaking might face practical challenges.  The explicit emphasis on fair presentation, combined with the strengthened focus on applying the materiality of information filter, gives companies greater flexibility in determining the meaningful content of their sustainability statements. This represents a further shift from a compliance-based to a principle-based approach. However, these changes also entail increased responsibility for the undertaking. Introducing additional reliefs would weaken this responsibility and create opportunities for misuse."]
["Survey","NABU","NGO","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","NABU","NGO","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","The number of datapoints in each standard represents the minimum necessary to ensure cohesive disclosure requirements, and, as a result, to maintain basic comparability and quality of disclosures.  We have not found any instance in which the ESRS impose excessive requirements beyond what is considered common practice or what is set out in internationally recognized reporting standards and frameworks, such as IFRS, GRI, or TNFD. In fact, the ESRS are generally more concise and less demanding. Further reductions—while still covering all ESG factors as required by the CSRD—would risk creating significant gaps in quality between ESRS disclosures and those based on other recognized standards."]
["Survey","NABU","NGO","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We support these changes, noting that they do not introduce any new burden.  This is particularly relevant for water-related metrics. To report on water consumption, undertakings are already required to calculate withdrawals and discharges, with these calculations—and the underlying data—subject to assurance. By elevating these implicit datapoints to explicit ones, the disclosure requirements become clearer compared with the previous ESRS, where some of these datapoints were presented as \"may disclosures.\" Whether these individual datapoints are ultimately disclosed remains appropriately subject to the undertaking's application of the materiality of information filter."]
["Survey","NABU","NGO","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We support these changes, noting that they do not introduce any new burden.  E2-4 on secondary microplastics is not a new datapoint, as correctly explained in the Rationale above. It is unclear why this item has been included in the question in its current form."]
["Survey","NABU","NGO","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","The ESRS, grounded in the materiality principle, the CSRD requirement to disclose impacts, risks, and opportunities along with their management, and the general principles of the Accounting Directive, are already subject to a fair presentation regime. Making this explicit serves to clarify the expectation.  It provides companies with clear guidance on the discretion and judgment they are expected to exercise when applying the standards, as well as the associated safeguards."]
["Survey","NABU","NGO","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We acknowledge the challenges of recalculating absolute values and recognize that financial institutions often manage GHG performance using intensity-based approaches. However, the global carbon budget is defined in absolute terms. Therefore, it remains essential that financial institutions disclose absolute targets to demonstrate how their strategies align with the economy-wide transition to net zero.  Absolute targets are critical for users of sustainability statements and for understanding the real-world climate impact of financed activities. While intensity measures provide insights into efficiency, they can obscure rising absolute emissions in expanding portfolios or sectors. In contrast, absolute values clearly indicate whether institutions are contributing to the necessary 90–95% global reduction in emissions by 2050, with steep cuts by 2030. Both intensity and absolute approaches rely on similar underlying data, and estimation challenges are not unique to the financial sector.  Allowing an exemption would undermine fairness in a sector-agnostic standard. Other industries could similarly argue for exceptions based on their own challenges, which would reduce comparability across sectors. Moreover, absolute financed emissions are already recognized in existing standards and regulations, including the SBTi Financial Sector Net-Zero Standard, the UNEP FI/NZBA recommendations, and the EU SFDR, all of which require or encourage absolute emissions disclosure. Exempting banks would risk misalignment and diminish the usefulness of reported data for stakeholders, including asset owners who rely on it for their own disclosures."]
["Survey","NABU","NGO","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","We welcome the removal of duplicated datapoints. The new, simplified framework allows companies to report on SFDR-related matters in a manner that aligns with the way their policies are structured. For users, this consolidation improves the ease of locating the relevant information."]
["Survey","NABU","NGO","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Measurable targets for biodiversity and ecosystems should be established and disclosed following the guidance and examples provided by relevant global frameworks. These include SBTN (Step 3 – Measure, Set & Disclose Targets), TNFD (components P1 and P2, Annex 5, sector guidance, and Target Setting guidance), as well as resources from the World Economic Forum on the Nature-Positive Transition."]
["Survey","NABU","NGO","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We note that the standard has been significantly streamlined, which improves readability and reduces the overwhelming level of detail. The shift of certain detailed questions to the ARs is generally understandable and beneficial. However, no further reductions are acceptable. As the standards develop and areapplied in practice, the level of ambition must increase to ensure meaningful disclosures. The results of the materiality analysis in the different EDs should mandatory to report. This \"bare-bones\" version, esp. with the reduced  E standards, should now also be easily applicable to smaller companies, which means that raising the thresholds is no longer necessary. On a positive note, the accompanying guidance document is a valuable resource and could be further expanded to support implementation. Overall, while the standard is more readable, it currently lacks the \"big picture\" perspective necessary for comprehensive sustainability assessment."]
["Survey","NABU","NGO","Germany","35.E4-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Transition Plan Incentive – The standard should include at least an incentive or ambition for companies to develop a transition plan, rather than only requiring disclosure if a plan already exists. This would encourage proactive planning and support meaningful progress.","E4","Disclosure Requirement E4-1 - Transition plan for biodiversity and ecosystems",""]
["Survey","NABU","NGO","Germany","35.E4-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","- Dependencies and Planetary Boundaries – Dependencies are now mentioned only once, and the concept of Planetary Boundaries, which provides essential guidance, has been removed. Understanding dependencies is particularly important for assessing ecosystem services, as they are critical to evaluating the interconnections and impacts within ecological systems","E4","Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems",""]
["Survey","NABU","NGO","Germany","35.E4-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The definition of what biodiversity offsetts  can be made clearer: Is the purchase / retiring of a voluntary biodiversity credit an offsett? Is giving NGOs money to do restoration work offsetting? Or is it meant in a strict mandartory offsetting scheme way?","E4","Disclosure Requirement E4-3 - Actions and resources related to biodiversity and ecosystems",""]
["Survey","NABU","NGO","Germany","35.E4-5."," Do you agree with the amendments of this chapter? ","I disagree","- Upstream and downstream supply chains are barely addressed, raising questions about how overall company performance can be adequately assessed. -The standard should clearly require disclosure of sites in or near biodiversity-sensitive areas, rather than limiting reporting only to sites determined to be connected to negative impacts. - The Land Use Metric based on an LCA, former ESRS E4 DR 36., which was a strong starting point, is no longer included. - ESRS E4 AR7 (amended): The use \"and/or\" could allow undertakings to  interpret as para. 20 does not apply if a site does not meet all 3 criteria. Instead, any of the 3 criteria (and in particular (a) or (c)) and Ecosystems change should be enough to trigger the disclosure.  Use \"or\" instead of \"and/or\".","E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Double materiality is crucial and must remain at the center of the ESRS framework and European Union sustainability regime for corporate reporting to be credible and useful.  The principle of \"materiality of information\" is concerning since it introduces a further filter for companies to not report information. For example, it represents a step backwards from ID-177, which says that most S1 metrics must be reported if S1 Own Workforce is material. It is essential to maintain the principle of fair presentation in the reporting standards.  It is positive that the revision of the AR 16 list of topics has maintained all of the sub-subtopics for S1 + S2. These are based on the list of social topics in the CSRD and should all be maintained. The emphasis on aggregation (as opposed to disaggregation) is concerning, as disaggregated information (both site-specific and country-specific) is key to understanding the distribution of IROs."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","It is important that companies report not just their net impact but also the gross impact should be reported. The recommended text preserves this principle."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","The proposed changes are helpful. However, para 113 is difficult to understand:  \"113. If the description of the material impacts, risks and opportunities prepared in accordance with [Draft] Amended ESRS 2 IRO-2 is not presented alongside the respective policies, actions and targets, the undertaking shall make explicit which policies, actions and targets relate to which material impacts, risks, or opportunities, in accordance with paragraph 22.\" Para 22 addresses the issue of appropriate aggregation or disaggregation of information on material impacts, risks and opportunities and their management, without setting any rules regarding the location of such disclosures depending (or not) on the level of aggregation."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The Exposure Draft removes duplications between the cross-cutting and topical standards. The preservation of the 4-part architecture in the social standards is important to respect the distinctiveness of different affected stakeholder groups.    However, we have two critical concerns. Firstly, the original DR in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. We welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened. Secondly, we strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics should not imply that entity-specific metrics for S topics should not be disclosed."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The \"may\" (voluntary) data points should not be eliminated. In many cases they are \"shall\" in GRI standards, so it is important to keep them to align with GRI standards. Also, many of them were originally proposed as mandatory by EFRAG to the EC. The first wave of reports show that many companies have reported some \"may\" data points. Retaining them would help ensure standardization/comparability between company reports. Almost all of the datapoints for non-employee workers are voluntary, thus most datapoints for this vulnerable group of workers has been lost. Also, important datapoints on full time versus part time workers has been eliminated."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","It is worrying that mandatory guidance in the Set 1 ESRS has been downgraded to \"non-mandatory\". Mandatory guidance is key to ensuring comparability and completeness of sustainability reporting. At a minimum, Non-mandatory Implementation Guidance (NMIG) should be included in the Delegated Act, and ideally called Mandatory Implementation Guidance.    A major point of concern is that ID-177, which provided guidance that most S1 metrics should be reported if S1 Own Workforce is material, has now been downgraded into NMIG. Instead, EFRAG should preserve and promote the guidance that most S1 metrics shall be reported."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","As a whole the reliefs go too far, overshooting the balance between cost/effort and transparency. There is a danger of enabling green/social washing. The relief for \"undue cost or effort\" is too vague thus leaving too much room for interpretation. The relief for direct data for value chain reporting is too extensive, as direct data is key for transparency. The relief for reporting on operations which are not \"significant drivers of IROs\" also opens up too much leeway for interpretation."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","These combined reliefs overshoot the balance between transparency and cost/effort and risk enabling green/social washing. At a minimum, there should be a time limit introduced for these reliefs on value chain metrics."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material. Reporting on financial effects is crucial to achieving the objective of putting sustainability reporting on the same level as financial reporting and integrating both. The European Union has recognised the value of a double materiality approach to corporate reporting which requires disclosure of both material environmental and social impacts, risks and opportunities as well financially material data, It is important to keep the requirement on businesses to analyse and understand the financial effects of their business model. This will ensure investors have access to credible data as well as providing the underpinning for future business planning."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","ESRS reliefs should not go beyond those set in IFRS. The principle of fair presentation needs to be protected to provide transparency on all material IROs. As noted in the response to question 15, it is also important to consider interoperability with GRI when considering changes to the ESRS, rather than only considering ISSB's standards."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","22.S1","Comments on deleted datapoints in ESRS S1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","The reduction in the number of mandatory and voluntary datapoints goes far beyond striking an acceptable balance. As mentioned above, the voluntary datapoints should be maintained to provide alignment with GRI, which is currently in the process of strengthening its labor standards, as well as guidance and standardization for companies reporting more than just the mandatory datapoints. An explicit quantitative goal of 50%+ reductions was never set by the European Commission for EFRAG. A number of S1 datapoint metrics have been eliminated which should be reinstated:  •\tS1-5 Employees: gender breakdown for zero-hour employees •\tS1-8 Diversity: age distribution; •\tS1-10 Social protection: reinstatement of retirement  •\tS1-12: Training and development: gender breakdowns, •\tS1-13 Health and safety: fatalities from ill-health for non-employees and other workers on site; •\tS1-14 Work-life balance: employees that took family related leave;"]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Adding a datapoint on training of the procurement team is needed to support the implementation of human rights in the supply chain. The addition of a datapoint on confirmed incidents of bribery is needed to improve transparency on the effectiveness of bribery/corruption policies and measures."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Agree that the following mandatory datapoint should be added: ESRS 2 General disclosures – BP 1 the undertaking shall state that the general requirements of ESRS 1 have been applied for the preparation of its sustainability statement."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","The \"fair presentation\" principle is essential to reduce the risk of green/social washing, as it emphasizes the full disclosure of all material impacts, risks and opportunities and their management. It is not understandable why this principle is under attack, as it is included as one of the general principles of the Accounting Directive."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","It is essential that financial institutions disclose absolute targets to assess how their strategies align with the economy-wide transition to net zero. Absolute targets are relevant for users of sustainability statements and for understanding the real-world climate impact of financed activities. While intensity measures provide insights into efficiency, they can mask rising absolute emissions in growing portfolios or sectors.   Granting an exemption would also undermine fairness in a sector-agnostic standard. Other industries could equally argue for exceptions based on their own difficulties, reducing comparability across sectors. Moreover, absolute financed emissions are already recognised in existing standards and regulations: the SBTi financial sector net-zero standard, the UNEP FI/NZBA recommendations, and EU SFDR all require or encourage absolute emissions disclosure. Exempting banks would risk misalignment and reduce the usefulness of reported data for stakeholders, including asset owners who depend on it for their own disclosures."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The \"top 10\" threshold for reporting country-level data on employment, collective bargaining and social dialogue is a major improvement over the current 10% employment threshold. An analysis of the first sustainability statements from Wave 1 companies shows that the current 10% threshold results in country-level disclosures on as little as 21% of total employees. More country-level information is needed to understand the distribution of impacts across countries, as well as whether employment thresholds for specific labour rights have been exceeded.  The new threshold does not require additional effort/cost by companies, since they must gather country-level data anyways to calculate the global figures. Furthermore, it does not result in extra datapoints, since the information currently is (and can be under the revised ESRS) reported as one table."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","An analysis of the first year ESRS reports shows that most companies are simply reporting that they pay minimum wages, whereas the intention (as outlined in the ESRS Basis for Conclusions) is that companies should be enabled to disclose commitments to paying a wage \"sufficient to support themselves and their families in dignity\" as well as the extent to which they do this. This shows that the methodology for non-EU countries needs to be changed. Furthermore, the new ILO agreement on a methodology for living wages needs to be taken into account. While the proposed new methodology takes a step forward in both regards, two key changes are needed:  •\tThe methodology for reporting on 'adequate wages' should measure actual wages against an adequate/living wage for all employees, not only those within the EU. In particular, for employees outside the EU, the methodology should allow employees' actual wages to be measured: o\tA) against the local legal minimum wage only when this is set in line with the ILO principles on estimating living wages; or o\tB) against living wage estimates that are set in line with ILO principles on estimating living wages. •\tCompanies should be able to rely on local legal minimum wages or living wage estimates when the authorities or organisations that set them provide public evidence of their alignment with the ILO principles for estimating living wages.  Furthermore, the transitional provision for the EU needs to be reinstated, as not all Member States have transposed the Adequate Minimum Wage Directive."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","The new, simplified framework makes it easier for companies to report on these SFDR-related matters in a way that corresponds to how their policies are set. For users, this consolidation makes it easier to locate the relevant information. However, the SFDR datapoints are very helpful and should only selectively be amended."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","The unadjusted gender pay gap should be kept as mandatory, since the methodology for calculating it is clear. The adjusted pay gap figure as voluntary. In practice many companies are reporting both figures, which is useful for improved transparency. However, since the methodology for calculating the adjusted figure is not standardized, the unadjusted should be kept mandatory."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","As detailed above, cumulative impact of the various reliefs is concerning."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The improved language on DMA is welcomed, including on the engagement with workers' representatives."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The proposed \"top 10\" threshold for the reporting of country-level information for employee headcount, collective bargaining and social dialogue is a significant improvement over the current 10% employment threshold. Country-level information needs to be reported in more detail, and on other metrics as well, in order to have more transparency on the distribution of impacts across countries. In the metrics, voluntary datapoints need to be reinstated as well as the datapoints on gender breakdowns, workforce age distribution, etc. detailed above need to be reinstated. The proposed new methodology for adequate wages outside of the EU also needs attention, and the transition language for EU member states needs to be reinstated, since the Adequate Minimum Wage Directive has not been implemented in some Member States. We would also like to reiterate our longstanding demand for including franchise workers in the S1 definition of own workers, as well as the need for sector-specific standards to supplement the Set 1 sector-agnostic standards."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We are concerned that the loss of many specific datapoints related to workers in the value chain will mean that disclosures about material impacts, risks and opportunities become more generic and have less information about the specific stakeholder groups because specifications about the level of granularity have been deleted. Many of the points that are being deleted from ESRS S2 had originally been included because they reflected effective practice in relation to improving supply chain labour rights, for example, AR 6 awareness of the impacts on value chain workers from an undertaking's strategy or business model, AR 20 illustrating how the perspectives of value chain workers have informed specific decisions or activities of the undertaking and AR 25 which looks at retaliation and whether workers can use grievance mechanisms confidentially."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","An explicit reference needs to be added to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, to clarify that metrics need to be reported in the case of entity-specific impacts."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","An explicit reference needs to be added to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, to clarify that metrics need to be reported in the case of entity-specific impacts."]
["Survey","European Transport Workers' Federation (ETF)","Trade union","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The definition of own workforce should be expanded to include franchise workers. The term \"non-employees\" should be supplemented with the phrase \"non-employee workers\" or \"non-employee workers in own workforce\"."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","The proposed amendment simplified the DMA process and keep an acceptable balance between simplification and robustness of the DMA. The elements that make the report relevant are still present. The very in-depth topics certainly force organizations to go further in the process, but the most important topics are still present.  Do you believe the removal of \"sub-sub-topic\" granularity could lead to underreporting of relevant issues? The removal of \"sub-sub-topic\" granularity could lead to underreporting, but it is up to the undertaking. It has the responsibility to be transparent with their stakeholders. If the undertaking report with the will to be transparent, it should not lead to an underreporting. On the other hand, the report will be less detailed but more accessible for the stakeholders.   Is the distinction between gross vs. net assessment of IROs sufficiently clear for practical implementation? The distinction is not enough clear. It should be more well explained in a paragraph dedicated to the subject. In the revised ESRS1 text, the term gross and net are only found in a few paragraphs without any real explanation. You have to do external research to get a real explanation of gross vs net.   Would you support relocating static disclosures (e.g., EU Taxonomy tables) to appendices to improve readability? The static disclosures are a necessity to obtain a complete report. They should be kept on the main part, but the detailed information like tables could be in the appendix.   Do you feel the guidance provides enough clarity for first-year reporting under the Omnibus? The guidance provides enough clarity for fist-year reporting under the omnibus. The guidance is well structured but could include some visualization of certain concepts like the DMA."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","The Appendix C clarify well how to consider remediation, mitigation and prevention implemented. But it could be interesting to let the company create a part in the report where, they present their old material impacts and how they success to remediate/mitigate/prevent them. The CSRD have for main goal to enable the comparison between companies. With it, companies can compare themselves on their strategy to remediate/mitigate/prevent their material impacts. This also reassures other stakeholders that the company is implementing actions that really work, and this gives the company credibility.  Do you consider the \"gross vs. net\" approach practical for assessing impacts across complex value chains? It is practical, it gives a good idea of the efficiency of the action the company implemented. And as said before it enables comparability and give credibility to the company in the front of stakeholders. Some issues can be met like the distinction can be difficult if actions are implemented since a longtime ago.  It could be helpful to give some case studies to have a better understanding.   How do you see this guidance affecting data collection efforts, especially where your company has limited control over upstream/downstream actors? The data collection should be difficult because some upstream/downstream actors are not in Europe and they do not feel concerned by European initiatives and consider, especially from the point of view of upstream actors, that the repercussions will be minimal compared to the investment they would have to put in place to meet European expectations. Unfortunately, this will not change unless European regulations are applied internationally and all countries commit to it, which is a utopia."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","In theory, it seems to be more user-friendly and more flexible. Include an executive summary and a more well-structured appendix to let only the main messages should be helpful to have a more accessible CSRD report.  Yes, clearer guidance on how to structure appendices would be helpful, like an study case or practical examples.   Do you find the concept of \"connected information\" sufficiently actionable in practice? The concept of \"connected information\" should be detailed in the ESRS 1. It is partially actionable in practice. In some case, in large organisations, to justify well, we should contextualise again so repeat some subject already explained before."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The PAT are a necessity to encourage the companies to implement solution to remediate/mitigate/prevent their impact. They should be mandatory but not the first years, the time for companies to find their bearings with the CSRD report. To resume I agree that the proposed amendments strike an appropriate balance but after few years the elements like PAT should not be a simple requirement but mandatory to encourage companies. If they are mandatory at a certain point, some companies will be \"lazy\" to implement solutions and will not progress."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","I agree, the \"may disclose\" brought a lot of confusion, it is a good thing to have them directly classified in the AR and located them directly under their related Disclosure Requirements.  Would a side-by-side comparison tool of old vs. new datapoints (e.g., Excel format) help your team navigate the changes more effectively? Yes, it could be helpful because the documents \"Log_of_Amendments_of_the_ESRS_Exposure_Draft_July_2025\" are really confusing with too much information. It's really messy to read."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","I believe during the assurance procedures the NMIG should be kept separate to avoid confusion. NMIG should be just used if the person does not understand a concept.  Would mapping tools between ESRS and IFRS/GHG Protocol improve the usefulness of NMIG for preparers and auditors? This could facilitate consistency between different types of reporting (financial, climate, etc.). But we must be careful that it does not become more confusing. Perhaps a separate file could be more accessible.  Do you see NMIG as a practical tool for internal training and onboarding of sustainability teams? NMIG is not famous, many people working in sustainability teams don't know what it is. There is a big lack of communication about this tool. This tool is well structured, but not really user friendly. I don't see it at all as a practical tool for internal training. It is not enough visual and accessible. You really have to dive into it to understand what it's about."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Excluding activities that are not significant drivers of IROs and joint operations without operational control when calculating non-climate environmental metrics, is a relevant tool but how to measure if the company does not interpret it too large.  The general \"undue cost or effort\", In which conditions we should consider than a requirement demands too many resources. Precise criteria are needed. Proposed Amendments provide sufficient relief and strike an acceptable balance, if some clear simple conditions are implemented.   Do you believe the reliefs sufficiently address concerns around operational control and joint ventures? The activities from operational controls and joint ventures would be considered, in majority, as unsignificant drivers of IROs according to the reliefs. For the first years of CSRD reports, this simplification is interesting, but for the future it must be re-included in order to encourage companies to act up to operational controls and joint venture activities, such as in five years.   Would clearer guidance on how to apply \"undue cost or effort\" across different metrics improve consistency? Yes please, company need more conditions to avoid risk interpretation of this concept.   Do you see challenges in estimating value chain metrics where data access is limited or unreliable? Yes, this is the case for actors who are outside the European Union, such as suppliers or customers, but also parent companies. Very important internal data within the company is difficult to obtain because the parent company, not wanting European regulations as a priority, can limit access to certain fundamental data in order to be transparent."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","I agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance, if a frame is well defined, such as some conditions and clear justifications.  Would a time-bound limitation on this relief improve comparability across reporting entities? Yes a time-bound limitation should be needed to improve comparability at condition it is staying flexible and feasible. If they are not limitation, companies can abuse this relief. This relief is relevant during the first years, giving time to companies to take ownership of the CSRD report and then to implement time limits.  Do you foresee difficulties in explaining improvement actions where data gaps are persistent or systemic? Data gaps can be persistent or systemic, especially from external actors, but if these actors find themselves with all their European stakeholders, some of whom are major, with the same requests concerning data, they will have to accept to provide them. The time-bound limitation could be a good solution."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","For the first few years, let's imagine 5 years, option 2 is preferable. Companies have time to take ownership of the CSRD reports, as well as all the stakeholders who support them in the process. After this period, the conditions must be tightened. This is where option 1 should be implemented, and why not make quantitative information completely mandatory in 10 years.  Clearer criteria are needed in this case to help reduce auditor interpretation risks such as clarify the acceptable level of uncertainty, what is meant by \"no separable data\", the minimum conditions for considering a business plan not reasonably available, etc."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","They have been sufficiently simplified. It is more relevant to disclose the financial effect of material topics. It keep the main topics and clarify the report to be more accessible for the stakeholders.   Do you find the remaining datapoints feasible to report on given current data availability and internal processes? The amendments give more flexibility, the remaining datapoints are generally feasible, especially for companies with mature sustainability data systems. However, for smaller entities or those early in their sustainability journey, challenges may persist due to limited internal processes or data granularity.   Would sector-specific guidance help improve consistency in reporting anticipated financial effects? Yes, sector-specific guidance would significantly improve consistency and comparability in reporting anticipated financial effects. Each sector has is own specificity, and risks.",null,null,""]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","The proposed Amendments achieve an appropriate balance thanks to the relief adoption, the alignment and references of the frames SASB, IFRS and ISSB.   Do you support the alignment of GHG boundaries with financial consolidation, or would operational control be more appropriate for your reporting structure? Aligning GHG boundaries with financial consolidation is consistent with IFRS S2 and the GHG Protocol, and supports integration with financial reporting. However, for organizations with complex ownership structures or joint ventures, operational control may offer a more accurate reflection of emissions responsibility. A dual approach should be considered. It means financial consolidation as the default, with optional operational control disclosure. It give more flexibility.   Would additional guidance on Scope 3 treatment improve alignment with GHG Protocol and reduce ambiguity? Yes, additional guidance on Scope 3 treatments are needed. It is the most challenging scope to identify and measure.  We need clear examples and guidance especially when a main actor is out of European Union."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","The proposed reduction strikes an acceptable balance, but over the years the \"shall disclose\" datapoints should increase progressively to still encourage companies to progress in a sustainable and transparent way.   Do you believe the prioritisation of quantitative over narrative datapoints improves usability and comparability? Yes, quantitative data improves usability and comparability between companies. They are needed.   Would a crosswalk between old and new datapoints help your team manage the transition more effectively? Yes, a crosswalk between the old and new datapoints would be extremely helpful for managing the transition, especially to identify which disclosures have been removed, merged, or reworded."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","Yes, these exceptions are appropriate and justified. The selected datapoints reflect core sustainability concerns, such as water usage, biodiversity transition planning, and business conduct. In most of the case, there are material.  Do you foresee any implementation challenges with the transition plan for biodiversity or procurement training disclosures? Biodiversity transition plans need a clear frame for each sector because, they don't have the same impacts like agriculture or a service company. I see less implementations challenge for the procurement training disclosures apart from a budget.  Would sector-specific examples help clarify expectations for these newly mandatory datapoints? Yes because not all sectors have the same level of impact on these newly mandatory datapoints."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","They are justified but some of them are difficult to measure like E2-4 and E5-5. Companies need guidance and standard to understand how measure them and to be comparable.  Do you foresee any challenges in collecting reliable data for E5-5, especially regarding unknown destinations? Yes many challenges are predictable from E5, like a clear definition to understand, what exactly is taken into account in this term, what are the expected measurement standards in order to be relevant and comparable and finally what to do if the information is not accessible, for example with an external actor who does not wish to communicate on this subject.  Would further guidance on defining \"critical and strategic raw materials\" improve consistency across sectors? Yes"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","Yes, the new threshold simplifies reporting while maintaining relevance by focusing on the top 10 countries.  Do you believe the new threshold improves relevance or could exclude key geographies with material social risks? This could exclude material elements but would be rather rare. Material topics tend to come from companies' major geographic areas. However, after a few years, the top countries by headcount should expand to cover more and more areas. Or, conditions should be implemented to include areas that have a material impact even if they are not in the top 10.  Would additional flexibility for regional aggregation help reduce reporting burden while maintaining transparency? Yes, allowing regional aggregation could reduce complexity while preserving transparency, especially for companies with fragmented operations."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","This methodology offers standardisation and comparability and encourage company with guidance on wage-setting and living wages  Would clearer guidance on wage estimation methods improve comparability across jurisdictions? Yes please, to standardize wage estimation.   Do you support alignment with ILO principles, even in countries with weak wage enforcement mechanisms? I support; companies must go beyond local obligations to ensure decent working conditions."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","Yes, the incorporation of SFDR PAI into the amended ESRS is well-balanced. The removal of overlapping or non-relevant datapoints improves clarity and reduces reporting burden, while maintaining alignment with SFDR objectives.  Do you believe the consolidation of social datapoints improves clarity or risks losing granularity? It improves clarity by avoiding redundancies. It could lost granularity, if we don't have sector-specific guidance where needed.  Would clearer mapping between SFDR and ESRS disclosures help streamline dual reporting obligations?  Yes please"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","It is unfortunate that Disclosure specifications and guidance for biodiversity/ecosystem targets have mostly been removed and leaving only one suggestion (AR 26). For things to change, you have to be demanding. Perhaps we should add disclosures as we go along.  Would referencing science-based frameworks like SBTN improve the relevance and credibility of biodiversity disclosures? Yes, this will strengthen the credibility of the objectives, improve comparability between companies, and align efforts with the latest scientific advances.  Do you believe more detailed guidance is needed to support target-setting for ecosystem restoration? In the future yes"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","The adjusted pay gap gives the opportunity to see where the women are underrepresented in certain positions such as management. It should be reintroduce for at least large organizations which have the resources to do it.   Would country-level breakdowns of the unadjusted pay gap improve the usefulness of the disclosure? Yes, the country-level breakdowns of the unadjusted pay gap improve the usefulness of the disclosure.  Do you believe adjusted pay gap data should be reintroduced as mandatory for large organizations? Yes"]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","Partially. While the new provisions (PAT disclosures and SME-specific elements) offer some coverage, they lack the direct visibility previously provided. To fully meet CSRD objectives, more explicit disclosures on payment terms and practices toward SMEs would be beneficial.  Do you believe the removal of direct payment practice disclosures weakens transparency on supplier relationships? Yes, removing direct disclosures reduces transparency on how companies treat their suppliers, especially SMEs. Payment practices are a key indicator of responsible business conduct, and their absence may obscure unfair treatment.  Would clearer guidance on SME identification and engagement improve reporting consistency? Absolutely. Clearer guidance on how to identify SMEs and report engagement practices would enhance consistency across companies and sectors and strengthen the relevance of disclosures for stakeholders."]
["Survey","FANUC","Preparer (non-financial preparing a sustainability report)","Japan","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Indeed, it was necessary to simplify certain CSRD disclosures, but it's important to keep in mind that companies are more likely to implement sustainable actions when they are strongly encouraged by regulations or influential stakeholders. That's why, after a few years of CSRD reporting, the level of ambition for disclosures should gradually increase. Of course, it's essential to listen to companies when they face challenges due to lack of data or resources, but we must also set progressively higher expectations. To support them, guidance should be simple and user-friendly, with clear visuals and practical tools."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","These changes should improve and standardise implementation of the materiality assessment by companies, while retaining key elements of the process – including those aligned with international frameworks like ISSB, GRI and the UNGPs. This should lead to more comparable and relevant reporting for investors.  However, we do not support deleting the following disclosure requirements: a)\tHow likelihood, magnitude, and nature of effects of risks and opportunities have been assessed. b)\tExtent to which and how process to identify, assess and manage risks, opportunities and impacts is integrated into overall management processes. c)\tHow process to identify, assess and manage impacts, risks and opportunities has changed compared to prior reporting period.  Investors need this information to understand how companies identify, assess and manage their sustainability matters – particularly for issues where processes and methodologies are still evolving. Further, such removals would compromise interoperability with international frameworks by removing requirements included within the ISSB standards (b-d) and GRI standards (a), risking comparability across investors' global portfolios.  To support the effective implementation of the materiality assessment, it will be important to develop sector-specific guidance once the ESRS Set 1 revision is finalised. This should help preparers to identify the likely material indicators for their industries – enabling more relevant information for investors – and build on international sector standards to improve global comparability.   Such guidance should also clarify how – and to what extent – financial institutions should consider their value chain (i.e. financial assets) in the materiality assessment, given data gaps from portfolio companies and current lack of guidance in this area. It should build on the UNGPs, OECD guidelines and other international reference points. For instance, clarification that financial institutions should focus on financial assets that are likely to give rise to material sustainability risks, opportunities and impacts would be helpful."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","The PRI supports this guidance, because it is likely to improve and standardise implementation of the impact materiality assessment by companies. This should lead to more comparable and relevant reporting for investors."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","The PRI supports these changes, as they are likely to improve the understandability of disclosures for investors without compromising the relevance or quality of information – while preserving information quality requirements which are important to ensure decision-useful data for investors."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The PRI supports most of the above changes, as well as the removal of duplications between cross-cutting and topical standards. This should clarify the requirements for preparers and improve implementation, enhancing the quality and understandability of disclosures, while also preserving many of the disclosures investors need on policies, targets and action plans.    However, we do not support the proposed deletion of requirements to disclose: •\tWhether and when an entity plans to implement policies, action plans and targets for material topics. •\tInformation on the progress of actions or actions plans disclosed in previous periods.  •\tKey actions taken (and the results) to provide for and cooperate in or support the provision of remedy for those harmed by actual material impacts.  Investors need this information to assess how and when companies' risks, opportunities and impacts are likely to evolve over time, and to inform their engagement with investees."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The PRI supports the above structural changes, because they are likely to improve implementation by companies and lead to better-quality and more understandable disclosures for investors.   However, we do not support the deletion of all \"may disclose\" datapoints and have made comments on specific datapoints in response to Part 3 of this consultation."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We recommend the NMIG is included within the Delegated Act. This would encourage preparers to consider it, thereby improving the relevance and quality of disclosures for investors, without increasing reporting burden given the voluntary nature of this guidance."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We support reliefs to facilitate implementation, provided that companies using these reliefs must still disclose efforts to meet relevant requirements (ESRS 1, Section 7.4), e.g. actions to address data availability concerns. This information can support investor engagement and would encourage improvements in reporting.   Further, we support preserving requirements to disclose metric calculation methodologies, to improve verifiability of reporting for investors.  We note that the reduced scope of the CSRD, as well as the Commission's proposed \"value chain cap\" limiting the information that companies subject to CSRD can request from value chain partners with fewer than 1,000 employees, will substantially reduce the availability and quality of sustainability reporting for larger companies and investors. For investors, this can complicate decision-making, increase the risk they are accused of greenwashing and heighten their dependency on service provider data.  While we recognise this is beyond EFRAG's remit, ensuring in the CSRD text that companies can ask suppliers for reasonable and proportionate information would reduce the need for companies to rely on this provision.    To improve implementation by preparers (and by extension data availability and quality for investors), we recommend that EFRAG provides guidance on when and how companies should use these reliefs. For example, the proposed relief allowing companies to exclude activities that are not significant drivers of risks, opportunities and impacts when calculating metrics should be explicit about specific environmental and social metrics  - such as GHG emissions under ESRS E1 and characteristics of employees and non-employees under ESRS S1 – that are relevant for all companies and whereby such exclusions are therefore not appropriate.  Finally, we oppose the introduction of reliefs relating to acquisitions and disposals acquired during the reporting period, which will reduce alignment with ISSB standards and cause differences in the reporting boundary compared to the financial statements – risking connectivity."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We support this relief, provided that EFRAG maintains the requirement for companies to disclose actions undertaken to improve the coverage of calculations in subsequent reporting periods – given this can support investors' engagement with companies.  Similar to our Question 17 response, to improve implementation by preparers (and by extension data availability and quality for investors), we recommend that EFRAG provides guidance on when and how companies should use this relief.  However, we recommend the \"undue cost and effort\" relief related to the disclosure of all metrics associated with an entity's own operations (as opposed to a smaller subset under the ISSB standards) is removed. In addition to compromising alignment with ISSB standards, this increases the risk that investors receive fewer datapoints needed for decision-making and stewardship."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ESRS should only permit Option 1, and require companies to justify only providing qualitative information should they choose to do so.  All investors, regardless of investment strategy, need disclosures on financial effects to understand the existing and future financial implications of exposure to sustainability-related risks and opportunities. These disclosures are especially useful to investors when quantitative information is disclosed – clearly illustrating the connections between sustainability risks and opportunities and specific financial statement line items – with qualitative information to provide additional context and explain methodological choices.  Further, mandating Option 1 is needed to ensure interoperability with the ISSB standards, which nearly 40 countries have adopted or are in the process of adopting – and by extension to ensure comparability of reporting across investors' global portfolios. Not requiring quantitative information about anticipated financial effects would result in the omission of information included in the global baseline.   We recognise that calculating financial effects of sustainability matters may present implementation challenges for preparers, particularly given methodological uncertainty. However, the availability and quality of such disclosures will continue to increase across industries as the ISSB standards are adopted, and there is a growing set of guidance (including from the ISSB) on how to report this information. By leveraging existing practice and providing clear guidance within the ESRS Non-Mandatory Implementation Guidance (NMIG), EFRAG can help to ensure effective implementation by preparers, thereby providing investors with the information they need."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","The PRI supports these requirements, as they will provide investors with the information they need on financial effects of climate-related risks and opportunities. We also welcome efforts to align them with equivalent requirements in the ISSB standards, as this will help to improve comparability for investors.",null,null,""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We welcome efforts to improve interoperability with the ISSB standards. Given nearly 40 jurisdictions have now adopted the ISSB standards or are taking steps to do so, better interoperability will improve comparability of reporting for investors.  However, there are several amendments within the simplified ESRS that risk compromising the high level of interoperability achieved between the current ESRS and the ISSB standards. As set out in Part 3 and our response to Question 19, this includes several removed and amended datapoints, which we would recommend are added back in and harmonised with the ISSB standards.  Further, we would suggest realigning the below structural features with the ISSB standards, to achieve further interoperability: •\tThe proposed reliefs beyond those included within the ISSB standards risk creating data gaps  This is because investors may not receive information that other companies reporting pursuant to ISSB standards provide. Therefore, these reliefs – relating to acquisitions and disposals acquired during the reporting period, and the \"undue cost and effort\" relief specifically related to the disclosure of metrics associated with an entity's own operations – should be removed. •\tThe requirement on ensuring that relevant information is not obscured should be harmonised with that of the ISSB standards, to improve both comparability and understandability for investors.  These changes would help to ensure that investors receive comparable reporting across their global portfolios."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","The PRI supports EFRAG's attempt to simplify the ESRS by reducing the number of datapoints, to ensure that requirements are both clear and manageable for businesses and sufficiently detailed and comparable for investors' decision-making. We welcome attempts to preserve datapoints across issue-agnostic and issue-specific ESRS that are aligned with international standards, or necessary for financial institutions to meet their own regulatory reporting obligations.   Further, we acknowledge and commend that EFRAG was able to remove datapoints while preserving a significant amount of the information for investors, through editorial changes, merging requirements and consolidating certain indicators across standards.  However, we do not support all of EFRAG's proposed deletions. Our recommendations on which specific datapoints should be retained – informed by the need for interoperability with international frameworks (including the ISSB standards, GRI standards and TNFD Framework) and datapoints prioritised in investor feedback we have received – can be found in Part 3 of our response. Of the datapoints EFRAG is proposing to delete, our response recommends that 53 of these are added back into the standards – approximately 5% of the 1,000+ datapoints that were in the ESRS prior to EFRAG's simplification proposal."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","The PRI supports these additions.   The inclusion of total discharges from own operations strengthens alignment with the TNFD core disclosure metrics, which include total volume of water discharged.   Disclosure of total water withdrawal is also valuable addition given that investors are particularly aware of water scarcity as a material risk. For instance, in 2022, 69% of listed equities reporting to CDP stated they had water-related risks, putting USD 225 billion of value at risk: https://planet-tracker.org/high-and-dry-how-water-issues-are-stranding-assets/. Water-related risks are also among the most recognised nature-related risks by financial institutions, with references to drought in annual reports and US mandatory financial statements increasing from 682 in 2019 to 1,739 in 2024 across Bloomberg World Large and Mid-Cap companies.   Finally, we support the requirement to disclose nature-related transition plans. Feedback from signatories and organisations such as the Nature Positive Initiative (NPI) indicates this is relevant information, and that an integrated approach to transition planning that considers multiple systemic risks has the potential to maximise synergies, avoid unintended consequences and build resilience. We recommend that guidance is provided on such transition plans to promote effective implementation of this disclosure requirement by the market."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","The PRI supports these additions and EFRAG's rationale to include them.   Reporting on whether the general requirements of ESRS 1 have been applied will provide investors with information about the quality of disclosures.  We also welcome the improved alignment with recent EU regulatory developments mentioned for E5-4. Investors support policy consistency and coherence, and this would also improve reporting burden.  Finally, waste for which the final destination is unknown is relevant information for investors, as this can indicate poor management (or mismanagement) of waste, and allow investors to track progress over time."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","The PRI supports this proposal. Explicitly requiring faithful representation by companies will help to ensure that disclosures are decision-useful for investors, by providing companies with clarity on the discretion and judgment they are expected to exercise when applying the standards.  However, we note that companies should still be prepared to justify materiality judgments to investors if requested. We recommend that this is clearly stated in the requirements. In addition, we recommend that additional guidance is provided on application of the \"fair presentation\" principle, particularly as it relates to impact materiality given this is beyond the scope of the ISSB standards."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We acknowledge that transition-supporting activities may improve intensity performance but still lead to short-term increases in absolute emissions, making longer-term absolute metrics useful. On the other hand, emissions intensity metrics show decarbonisation progress independent of business volume changes, while medium and longer-term absolute figures remain essential for calculating financed emissions and portfolio-level climate risk assessment. Therefore, rather than a full exemption, we recommend financial institutions are required to disclose both metrics with relevant context, explaining how transition activities may impact each measure differently."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The PRI does not support this change, which would require companies to assess whether wages established by national law or collective agreements align with ILO wage-setting principles.   As noted by the abovementioned Board members, a nominal compliance with these principles does not ensure that wages are adequate or fair. Further, the proposed disclosure directs companies to prioritise the use of local legal minimum wages when calculating the gap between lowest wages and (often much lower) \"adequate\" wages for employees outside the EU – allowing companies to report minimum wages without an adequate wage guarantee.  Therefore, the ESRS should require \"adequate wages\" to be measured: (i) against the legal minimum wage only where this is set in line with the definition of an adequate minimum wage under EU law, or the ILO principles on estimating living wages; and (ii) against living wage estimates that are set in line with ILO principles on estimating living wages. They should also be clear that companies should apply only option (i) if the authorities that set the minimum wage provide public evidence that it is in line with the EU definition of an adequate minimum wage or the ILO principles on estimating living wages. Finally, companies reporting on adequate wages should be required to disclose calculation methodologies, to improve verifiability for investors."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","The PRI supports overall efforts to simplify the standards while maintaining datapoints investors need to calculate SFDR Principal Adverse Impact (PAI) indicators.  While we support EFRAG's consolidation of disclosures on policies related to human rights and alignment with the UN Guiding Principles and OECD Guidelines for Multinational Enterprises, we recommend this datapoint is reworded to more closely align with investors' information needs under SFDR, focusing on processes and compliance mechanisms rather than whether a relevant policy is in place.   In addition, looking ahead, it will be important to ensure alignment between the ESRS and the future SFDR, given this regulation is likely to be subject to revision."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We support the provision of guidance on what biodiversity and ecosystems-related targets can cover. This should reference industry-led guidance (including from TNFD, the Science Based Targets Network (SBTN) and the Food and Agriculture Organisation (FAO)) where possible.   However, we do not support the deletion of the following disclosure requirement within ESRS E4, as it is needed for investors to understand the credibility of targets disclosed. •\tWhether the targets are informed by, and/or aligned with the Kunming-Montreal Global Biodiversity Framework, relevant aspects of the EU Biodiversity Strategy for 2030 and other biodiversity and ecosystem-related national policies and legislation."]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.ESRS2_BP-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tDescription of planned actions to improve accuracy in future of metrics that include value chain data estimated using indirect sources •\tExplanation of changes in preparation and presentation of sustainability information and reasons for them.  This information can help investors to understand past and future changes to sustainability reporting, and engage on this basis. Further, given it is included in the ISSB standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.","ESRS2","BP-2 - Specific information if the undertaking uses phasing-in options",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.ESRS2_GOV-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tNumber of executive members •\tNumber of non-executive members •\tDescription of management's role in governance processes, controls and procedures used to monitor, manage and oversee impacts, risks and opportunities •\tDescription of how oversight is exercised over management-level position or committee to which management's role is delegated •\tInformation about reporting lines to administrative, management and supervisory bodies. •\tDisclosure of how dedicated controls and procedures are integrated with other internal functions •\tDisclosure of how administrative, management and supervisory bodies and senior executive management oversee setting of targets related to material impacts, risks and opportunities and how progress towards them is monitored  Investor input has indicated these datapoints are decision-useful. This information would help investors to understand the internal controls that are in place for management to monitor, manage and thereby react to sustainability matters. Further, given these datapoints are included in the ISSB and/or GRI standards, removing them would compromise global interoperability, and by extension comparability of reporting for investors.  In addition, the PRI does not support the proposed removal of the following requirement: •\tDisclosure of whether, by whom and how frequently administrative, management and supervisory bodies are informed about material impacts, risks and opportunities, implementation of due diligence, and results and effectiveness of policies, actions, metrics and targets adopted to address them.  This information would help investors to understand the internal controls that are in place for management to monitor, manage and thereby react to sustainability matters. Further, given it is included in the ISSB and GRI standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","ESRS2","GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.ESRS2_GOV-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tWhether and how and sustainability-related performance metrics are considered as performance benchmarks or included in remuneration policies.  This information would help investors to understand management's incentives to address material sustainability matters, and by extension how well these are managed and how they are likely to change in the future.  Further, given it is included in the ISSB standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","ESRS2","GOV-2 - Integration of sustainability-related performance in incentive schemes",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.ESRS2_SBM-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tDescription of key stakeholders. •\tDescription of categories of stakeholders for which engagement occurs. •\tDescription of how stakeholder engagement is organised. •\tDescription of purpose of stakeholder engagement.   This information would help investors to understand the materiality assessment process, upon which disclosures are based.   Further, given it is included in the GRI standards and TNFD Framework, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","ESRS2","SBM-2 - Interests and views of stakeholders",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.ESRS2_SBM-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tDisclosure of reasonably expected time horizons of material impacts.   This information is crucial to investors' understanding of a company's material impacts.  Further, given it is included in the GRI standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","ESRS2","SBM-3 - Interaction of material impacts risks and opportunities with strategy\nand business model, and financial effects",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.ESRS2_IRO-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tDescription of how likelihood, magnitude, and nature of effects of identified risks and opportunities have been assessed. •\tDescription of extent to which and how process to identify, assess and manage impacts and risks is integrated into overall risk management process and used to evaluate overall risk profile and risk management processes. •\tDescription of extent to which and how process to identify, assess and manage opportunities is integrated into overall management process.  •\tDescription of how process to identify, assess and manage impacts, risks and opportunities has changed compared to prior reporting period.   This information would help investors to understand the materiality assessment process, upon which disclosures are based, and the degree to which this is incorporated into companies' wider policies and procedures.   Further, given these datapoints are included in the ISSB standards, removing them would compromise global interoperability, and by extension comparability of reporting for investors.  Finally, we recommend clarification within paragraph AR22 that TNFD LEAP is relevant for the materiality assessment of environmental impacts. The current wording may falsely suggest it is only useful for the purpose of screening site locations.","ESRS2","IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E1-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tHow targets are compatible with the limiting of global warming to 1.5°C in line with the Paris Agreement. •\tTaxonomy-aligned revenue and capital expenditure (CapEx) supporting transition plans and, if applicable, planned CapEx. •\tInformation on whether the company is excluded from EU Paris-aligned Benchmarks.  Information on compatibility with 1.5°C through aligned pathways and scenarios is relevant for investors assessing alignment of their overall portfolios with climate objectives. Without this information, investors will need to assess companies' alignment themselves or rely on third parties.  Reporting on Taxonomy alignment is also relevant to investors, particularly as a key indicator of transition plan credibility and effective implementation.  Finally, investors need disclosures on exclusion from EU Paris-aligned Benchmarks to fulfil their own reporting of Principle Adverse Impacts (PAIs) under SFDR and assess compliance with ESMA fund name guidance.  On the other hand, we support the proposal to preserve qualitative reporting on carbon lock-in as part of companies' overall dependencies, given this information is helpful for investors to understand the nature and feasibility of transition plans. The more explicit reference to dependencies will also help to improve alignment with the Transition Plan Taskforce (TPT) Disclosure Framework (which is now ISSB guidance on transition planning).  Further, we welcome the addition of reporting on the role of management in transition planning, given this indicates the importance placed on such plans and how likely they are to be achieved.","E1","Disclosure Requirement E1-1 - Transition plan for climate change mitigation",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E1-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","We note that several changes have been made in this section which create further differentiation with ISSB requirements. We recommend that scenario analysis requirements are aligned with the ISSB standards, to ensure that investors receive adequate information about how this is conducted – to enable them to understand and assess the results – and to ensure comparability of reporting across portfolios.","E1","Disclosure Requirement E1-2 - Climate-related risks and scenario analysis",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E1-8."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tQuantitative and qualitative information regarding the progress of actions or action plans disclosed in prior periods.  •\tThe extent to which the undertaking's Scope 3 greenhouse gas emissions are measured using inputs from specific activities within the entity's upstream and downstream value chain.  This first requirement would help investors to understand how companies are addressing their materiality sustainability matters, and by extension how these are likely to change in the future. Further, given this datapoint is included in the ISSB standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.  The second requirement, in turn, would help investors to understand how Scope 3 GHG emissions are calculated, compared to other portfolio companies, and improve verifiability of reporting.. And similarly, given this datapoint is included in the ISSB standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.  Finally, under EFRAG's proposed requirements, entities may need to measure their emissions using both the financial control organisational boundary and operational control method, whereas the ISSB standards (in alignment with the GHG Protocol) require the use of a single approach to measure emissions. To ensure comparable emissions reporting for investors, the ESRS should adopt the same requirements as the ISSB standards.","E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E2-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDisclosure of whether and how policy addresses substituting and minimising use of substances of concern and phasing out substances of very high concern.    Investor input has identified this datapoint as decision-useful.  Further, we recommend that the reference to \"dependencies when relevant\" is amended to remove the words \"when relevant\", to encourage companies to report on these and align with the TNFD Framework.","E2","Disclosure Requirement E2-1 - Policies related to pollution",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E2-4."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDescription of changes over time (pollution of air, water and soil).   Given it is included in the TNFD Framework, removing it would compromise global interoperability, and by extension comparability of reporting for investors.","E2","Disclosure Requirement E2-4 - Pollution of air, water and soil",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E4-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tExplanation of whether and how biodiversity and ecosystems-related policy addresses social consequences of biodiversity and ecosystems-related impacts.    This datapoint should be maintained to encourage consideration and disclosure of interconnected issues and their synergies and trade-offs.  Further, given it is included in the TNFD Framework and GRI standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","E4","Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E4-5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","To mitigate risks to consistency and relevance of reporting from removing biodiversity metrics from ESRS E4, we recommend that the TNFD core global disclosure metrics are referenced (when related to topics relevant to biodiversity and ecosystems). This should include the following metrics: •\tTotal spatial footprint (km2) •\tExtent of ecosystem use changed, restored, and sustainably managed •\tQuantity of high-risk natural commodities sourced, including under a sustainable management plan or certification programme (tonnes) •\tProportion of high-risk activities operated under appropriate measures to prevent unintentional introduction of invasive alien species  This approach would ensure relevant disclosures and international alignment – particularly given ISSB's commitment to leverage TNFD's work in its own nature work – and build on existing market practice.  In addition, we do not support the option to report only metrics for locations relevant to existing sustainability objectives (AR7(b)). Such metrics should be reported in addition to (rather than instead of) those related to locations where the undertaking has identified material impacts, risks and opportunities arising from its direct operations – or locations that are significant drivers of material impacts, risks and opportunities. Otherwise, there is a risk that companies will significantly narrow the scope of locations disclosed, despite material risks to operations. We also recommend that this requirement is included within ESRS E2, 3 and 5, given this reporting is relevant for these issue areas.  Finally, we do not support the proposed removal of the following requirement: •\tDisclosure of how pathways of introduction and spread of invasive alien species and risks posed by invasive alien species are managed   This datapoint (also present in TNFD and GRI) should be maintained to encourage consideration and disclosure of information on invasive species, given this is a key driver of biodiversity loss and otherwise infrequently mentioned in ESRS E4.","E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E5-4."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDescription of methodologies used to calculate data and key assumptions used.  Transparency on calculation methodologies is critical for verifiability of the information.  Further, given it is included in the TNFD Framework, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","E5","Disclosure Requirement E5-4 - Resource Inflows",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.E5-5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tNon-recycled waste •\tDisclosure of materials that are present in waste.   While non-recycled waste can be derived given the requirements to disclose total amount of waste and total amount recycled, this datapoint would support transparency and facilitate investor understanding and reporting – especially as this is a data point required under SFDR – with limited additional effort for preparers.  The second datapoint should also be added back in, as the new requirement to simply disclose \"key materials\" leaves room for reporting entities to only report some types of waste materials, and obscure other materials with potential cumulative impacts. Further, given this requirement is included in the TNFD Framework and GRI standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.","E5","Disclosure Requirement E5-5 - Resource outflows",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S1-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDisclosure of whether and how policies are implemented through specific procedures to ensure discrimination is prevented, mitigated and acted upon once detected, as well as to advance diversity and inclusion.   This datapoint is needed to ensure that relevant information is disclosed. Investors recognise discrimination policies as key policies that companies should have in place, and that general anti-discrimination commitments are often not specific enough unless they are backed up by specific processes and actions.  Further, given this datapoint is included in the GRI standards, removing them would compromise global interoperability, and by extension comparability of reporting for investors.","S1","Disclosure Requirement S1-1 - Policies related to Own workforce",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S1-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDescription of additional initiatives or actions with primary purpose of delivering positive impacts for own workforce.  Given it is included in the GRI standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","S1","Disclosure Requirement S1-3 - Actions and Resources related to Own workforce",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S1-6."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tCharacteristics of undertaking's employees - information on employees by region [table] •\tNumber of employee who have left undertaking  •\tPercentage of employee turnover •\tDisclosure of contextual information necessary to understand data (employees)  •\tNumber of full-time employees by head count or full time equivalent •\tNumber of part-time employees by head count or full time equivalent •\tDescription of methodologies and assumptions used to compile data (non-employees)  •\tNon-employees numbers are reported at end of reporting period/average/other methodology •\tDisclosure of contextual information necessary to understand data (non-employee workers)   Investor input has identified these datapoints as decision-useful, for the following reasons: •\tInvestors can use information on regional makeup of the workforce when conducting a human rights risk assessment. •\tEmployee turnover is a key indicator of a company's general health, as well as its treatment of its employees.  •\tContextual information, together with information on the number of full-time and part-time employees, is key to understanding a company's approach to its workforce, given that part-time contracts may be used to circumvent legislative requirements. *       Information on methodology and assumptions is important to ensure verifiability of data for investors, while contextual information is needed to enhance understandability of disclosures and ensure that all relevant information is provided.  Further, given these datapoints are included in the GRI standards, removing them would compromise global interoperability, and by extension comparability of reporting for investors.","S1","Disclosure Requirement S1-6 - Characteristics of non-employees in the undertaking’s own workforce",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S1-10."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tWhether all employees in own workforce are covered by social protection, through public programs or through benefits offered, against loss of income due to retirement.  This information is relevant to investors adopting wider and long-term horizons in an age of increasing demographic changes, and stress on public social security systems.  Further, given this datapoint is included in the GRI standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.","S1","Disclosure Requirement S1-10 - Social protection",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S1-13."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tNumber of cases of recordable work-related ill health of non-employees •\tNumber of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health related to non-employees •\tPercentage of own workforce who are covered by health and safety management system based on legal requirements and (or) recognised standards or guidelines and which has been internally audited and (or) audited or certified by external party.  Investor input has identified these datapoints as decision-useful. This information is key to understand working conditions, including of the non-contracted workforce.  Further, given they are included in the GRI standards, removing these datapoints would compromise global interoperability, and by extension comparability of reporting for investors.","S1","Disclosure Requirement S1-13 - Health and Safety metrics",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S1-16."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDisclosure of the status of incidents and/or complaints and actions taken.  This datapoint is relevant as investors need this information to understand the time it takes for companies to respond to issues.  Further, given this datapoint is included in the GRI standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.","S1","Disclosure Requirement S1-16 - Incidents of discrimination and other human rights incidents",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S2-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDescription of initiatives or processes whose primary aim is to deliver positive impacts for value chain workers and are designed also to support achievement of one or more of Sustainable Development Goals  This datapoint is useful for investors assessing their contribution to (or alignment with) the SDGs.  Further, given it is included in the GRI standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","S2","Disclosure Requirement S2-3 - Actions and resources related to value chain workers",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S3-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirements: •\tDescription of types of affected communities subject to material impacts •\tType of communities subject to material impacts by own operations or through value chain •\tDescription of activities that result in positive impacts and types of affected communities that are positively affected or could be positively affected   Removing these datapoints would limit understanding of a company's impacts, and of whether proper stakeholder mapping (and therefore engagement) has been carried out. Further, given they are included in the GRI standards and TNFD Framework, removing these datapoints would compromise global interoperability, and by extension comparability of reporting for investors.  In addition, we note the requirement to disclose the occurrence of material negative impacts on affected communities is phrased in a way that may prompt companies to limit disclosure to impacts from the green transition, and in particular the effects of mines. While this is relevant information, we recommend clarifying that these should not be the only types of impacts disclosed.","S3","Disclosure Requirement S3-1 - Policies related to affected communities",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S3-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDisclosure of how the undertaking assesses the effectiveness of its engagement with affected communities •\tIf applicable, that a company has not adopted channels for raising concerns or does not support the availability of such a channel, and (if applicable) a timeframe in which they aim to have such channels or processes in place  Regarding the first requirement, given that assessment of engagement can be carried out in a number of ways, investors would benefit from clarity about how this is achieved – so they can assess whether engagement has been carried out properly.  The second requirement should be restored as investors would benefit from knowing whether this: (i) does not exist; or (ii) exists and is not being reported on – and whether this will be established in the future.","S3","Disclosure Requirement S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S3-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDisclosure of whether and how it is ensured that own practices do not cause or contribute to material negative impacts on affected communities     This datapoint is a key component of due diligence processes under the UNGPs and OECD Guidelines.  Further, given this datapoints is included in the GRI standards, removing it would compromise global interoperability, and by extension comparability of reporting for investors.","S3","Disclosure Requirement S3-3 - Actions and resources related to affected communities",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S4-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tDisclosure of how effectiveness of engagement with consumers and end-users is assessed  Assessment of engagement can be carried out in a number of ways. Therefore, investors would benefit from clarity about how this is achieved, so they can assess whether engagement has been carried out properly.  Further, given it is included in the GRI standards, removing this datapoint would compromise global interoperability, and by extension comparability of reporting for investors.","S4","Disclosure Requirement S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy",""]
["Survey","Principles for Responsible Investment (PRI)","Association of financial institutions","United Kingdom","35.S4-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The PRI does not support the proposed removal of the following requirement: •\tInitiatives or processes whose primary aim is to deliver positive impacts for consumers and/or end-users are designed also to support achievement of one or more of Sustainable Development Goals  This datapoint is useful for investors assessing their contribution to (or alignment with) the SDGs.  Further, given these datapoints are included in the GRI standards, removing them would compromise global interoperability, and by extension comparability of reporting for investors.","S4","Disclosure Requirement S4-3 - Actions and resources related to consumers and end-users",""]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Materiality will still be difficult to assess and we suggest greater use of illustrative examples and Practical guidance. This is a whole new realm fro preparers and the more guidance afforded the easier the implementation"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Actual negative impacts should be considered on an impact-consequence matrix and thus materiality determined"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","Connected information, discouraging fragmentation and/or repetition of information has been largely achieved.  Simplicity of report preparations and presentation of such reports in a concise understandable form is the balance that needs to be struck"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Only the relevant and applicable shall data points should be retained and proposed amendments strike an appropriate balance between  (1) prescriptiveness of the requirements and preparation effort from the one hand, and  (2) need for relevant and comparable information from the other"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","The 3 changes should achieve the intended objective"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","We agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders' demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB's IFRS S1 and S2"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","non"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Both options are amenable."]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","non",null,null,""]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","non"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","non"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","The compliance approach is generally a hybrid approach, that is check list and tailored."]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Their rationale for seeking such exemptions are reasonable and could include other sectors"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","Country by country disclosure should be replaced by uniform disclosure across countries.  This is more so since the burden to prepare the information per the new requirement is estimated to be limited."]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","A simple universal method of calculation of minimum wages across jurisdictions should be availed in line with ILO standards. The ILO standard is a minimum baseline expectation. cost of living standards differ across the world and also between and within different regions of the same country so this will in effect be a complex measure and may give results that may be construed wrongly."]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","non"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","non"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","The maintenance of the global unadjusted pay gap and removal of the adjusted gender pay gap would ease application."]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","Yes, the objectives of the CSRD in respect to the protection of SME's"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Mo Chartered Accountants (Zimbabwe)","Auditor","Zimbabwe","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"These will be subject to continual change and amendment once practical implementations takes effect. Not all considerations could have been foreseen and changes will be necessary over time.  Due to its infancy, there are rightly very many exemptions and reliefs and this may have an impact on comparability and consistency. These may be removed in future once the standards become more commonplace."]
["Survey","AP2","Asset manager/Investor","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","AP2 believes it is important to preserve the essential alignment of double materiality with risk-based due diligence (including steps for identifying, assessing, and prioritizing impacts based on their severity and likelihood) under the international standards of the UNGPs and OECD Guidelines.     AP2 also welcomes the current specificity of the impact materiality assessment process. It provides much-needed clarity for companies that are new to risk-based due diligence or are undertaking an impact materiality assessment for the first time. This clarity helps ensure that expectations remain consistent with international standards already being followed by many companies. Removing them would lead to diverging and incompatible approaches to impact materiality, reduce comparability between companies' materiality assessment results, and reduce compatibility with international standards."]
["Survey","AP2","Asset manager/Investor","Sweden","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","AP2 support efforts to improve transparency and accountability regarding wage practices in corporate reporting. We welcome the progress in ESRS, particularly the inclusion of collective bargaining and periodic review of minimum wages, but further refinement is necessary to ensure fair remuneration for all workers. The current draft could be discriminating to non-EU workers.      1. Defining \"adequate\" wages    The draft lacks a clear definition of \"adequate wage\". Since the ILO provides a globally recognized definition and methodology for living wage, we recommend aligning ESRS with this standard. To ensure meaningful assessment, companies must disclose which prong of the methodology is applied; otherwise, investors cannot evaluate the robustness or comparability of reported figures.       2. Non-EU workers and hierarchy    The methodology discriminates against workers outside the EU, as their wages are measured against the statutory minimum wage, compared to the EU Adequate Minimum Wage Directive for EU employees. The standard for non-EU employees is with that significantly lower as minimum wages in these countries often are substantially below what is required to meet basic needs. This creates a misleading picture and undermines the objective of fair remuneration.    Furthermore, the current hierarchy prioritizes the use of minimum wages over living wage estimates, which can lead to distorted reporting outcomes.    To avoid such misrepresentation and address the issue of discrimination, the hierarchy for all employees should be as follows:    • Use the legal minimum wage only where it is demonstrably aligned with the definition of an adequate minimum wage under EU law or with the ILO principles on estimating living wages;    • Otherwise, apply living wage estimates that are aligned with the ILO principles on estimating living wages."]
["Survey","AP2","Asset manager/Investor","Sweden","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Commentary to question 14:  AP2 encourage EFRAG to preserve the core four-part architecture of the social standards (covering own workforce, value chain workers, affected communities, and consumers/end-users). This structure provides companies with a clear and practical framework for navigating, assessing, and reporting on social issues. It helps ensure that materiality assessments are comprehensive, avoids blind spots, and fosters a common language for internal communication across functions. Reducing the social standards to a single category would risk oversimplifying complex realities and undermine the effectiveness and comparability of social disclosures. Maintaining this architecture is essential for meaningful and consistent sustainability reporting."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","The inclusion of the \"executive summary\" as a structural element is welcomed."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Agreement: - Reduction of \"shall\" datapoints - Improvement/clarity of connectivity \"PAT-to-IROs\" Disagreement: - Elimination of \"plans to implement a PAT\" (incl. timeline) delutes transparency and might lower incentives for undertakings"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","300 words for all NMIGs too short. Therefore only most relevant here:  Integration of some NMIGs as ARs for clarity and examples.   \"NMIG 11\" should be an AR. Moreover, it should be added that: \"Such restriction to metrics (activity/location/asset system boundaries) must be transparently disclo-sed, e.g. via footnotes, in the specific disclosure.\" Also connected to \"NMIG 9\": if this is applied high transparency needed to protect comparability of information.  \"Mapping of sub-topics\" why is this not an Appendix - similar to ESRS 1 Appendix A - or even merged with Appendix A?  \"Flowchart\": 1) Should be added as Appendix to ESRS 1. 2) Why is ESRS 2, 30 (\"disclose fact not adopted\") not added to the decision tree after the second \"No\"?  \"Example of structure\" should be added to ESRS 1 as Appendix, similar to existing ESRS 1 Appendix D.  \"Example of incorporation\" should be  added to ESRS 1 as Appendix (cf. ESRS 1 Appendix F). ESRS2: \"NMIG 1\"  proposed to delete or add (a) into relevant ESRS 2, GOV-1, 9 - preferably deleted. Need for (b) not directly obvious, value of explicitly stating \"experience\" for users not tangible - proposed deletion. \"NMIG 3\" since it can be perceived, that some uncertainty is around the \"due diligence\": add as AR to ESRS 1 chapter 4 as Core Elements (a to e). Maybe shorten subpoints by only referencing to specific DRs. \"NMIG 4\" (a) seen as not critically benefical to proposed amended ESRS 2 GOV-4. If (b) \"findings\" is seen as critical, add as AR in ESRS 2 GOV-4.  \"NMIG 3 for para. 22\" if fact \"or in the upstream and downstream value chain\" is deemed to be essential, must be added to ESRS 2, GDR-P as AR. \"NMIG 6 for para. 28\" should be AR in corresponding E1."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","Partial scope for the underlying calculations might delute comparability and transparency. It should therefore be mandatory to transparently highlight if and where this has been applied. E.g. in form of footnote directly placed at the metric disclosure and within the explanations of ESRS 2."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Quantification is paramount for capturing, measuring and managing. Chasing the goal to improve contemplation and reporting on specific ESG-topics, it would be negligent to limit the ESRS only to qualitative information. The given conditions in \"Option 1\" (connection to topic/material IRO, level of uncertainty, derivation, skills/capabilities, resources) appear sufficient to expect reporting."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","Complete agreement of necessity to have this DR. Concerning 40. (e): unclear connection to \"leverage\" out of ANNEX II. Might be changed by removing bold.  Concerning 41. (f): similar to 40.(e) unclear connection to \"leverage\" (ANNEX II), proposal to remove bold. Concerning 42: change \"assets or revenue\", proposal to change \"or\" in \"and\" to foster contemplation and reporting.",null,null,""]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I disagree","Point 3 (\"undue cost or effort\") goes further than IFRS one. If generally applied it could lower standardisation and comparability of sustainability statements. If kept, clearer guidances and ARs on how untertakings should transparently disclosed are advised."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Previous AR 26 states \"may expressed as\", it is therefore not exhaustive. Agreement that AR 26 should be kept. Need for further revision, of dynamic landscape/latest trends, not seen as compulsory."]
["Survey","GKK Partners","Consultant (including software vendor)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","University of Gothenburg","Academia","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Overall, there is a clear linguistic improvement in the ESRS. The text is shorter, more focused and easier to read.  There is an attempt in the revised ESRS to simplify the process of determining impact materiality. However, this cannot get around the basic question that impact materiality is related to users that are not well defined and unspecific decisions to be taken by such users. To simplify the process, the revised ESRS appear to define impact materiality in terms of innate characteristics of phenomena. It is unclear how such a focus is logically consistent with the concept of materiality, which has to do with the interaction between information and users.  A reason for the limited simplification in ESRS 1 is that the standard is still based on the unchanged CSRD. This relates to an additional question which the EFRAG cannot do much about at present but that could create difficulties for preparers. A simplified CSRD is likely to result in a new revision to ESRS. While this would potentially allow for a true simplification of, e.g., ESRS 1, it would mean that preparers must adopt a third version of ESRS, all issued within a limited timeframe."]
["Survey","University of Gothenburg","Academia","Sweden","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","The introduction of \"fair presentation\" might be difficult to implement in a newly regulated field such as ESRS. The concept has a long history in financial accounting. There, however, the meaning of the concept has gradually developed in practice over time. It will take some time before practice defines the meaning of fair presentation based on ESRS. Therefore, the concept is unlikely to be helpful in the early implementation of ESRS."]
["Survey","University of Gothenburg","Academia","Sweden","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","European Biogas Association","Other - please specify (required)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","In ESRS E1, under Disclosure Requirement E1-8 and Application Requirements 19 to 25: The proposed amendments to ESRS E1-8 and AR 19–25 reflect progress in simplifying GHG emissions reporting, in line with EFRAG's simplification objectives. Notably:  •\tThe alternative possibility to use ISO 14064-1:2018 (instead of only the GHG Protocol standard) is made more explicit for each Scope of emissions. •\tRemoval of the confusing unspecified reference to \"principles of the GHGP\".  However, the standard still lacks sufficient clarity and practical applicability.  1) Use of market instruments in Scopes 1 and 3. While AR 21 and 25 refers to the GHG Protocol Standard and to ISO 14064-1:2018, they fail to recognise regulated market-based instruments such as RED-compliant Proofs of Sustainability for biomethane purchases. These instruments are legally required under EU law and widely used to account for emissions performance. Consistent with the simplification rationale under Lever 2 , AR 21 should explicitly accept RED-compliant Proofs of Sustainability under Scopes 1, 2 and 3.   2) Related to \"better connectivity with corporate reporting\", EBA highlights the lack of consistency of Application Requirement 21 paragraph e) with existing climate reporting standards and practices. In AR 21, all \"biogenic emissions from the combustion or biodegradation of biomass (in particular, CH4 and N2O)\" should be reported under Scope 1, while climate reporting practices (including the GHG Protocol) report those biogenic emissions off-scope (with the possible exception of CH4 and N2O).  To ensure interoperability and reduce inconsistencies, AR 21 e) should be aligned with this and with Disclosure Requirement E1-8 paragraph 33. Contrary to what Paragraph 264 of the Basis for Conclusions states, under GHG Protocol Scope 2 Guidance, \"Companies should separately report the biogenic CO2 emissions from electricity use (e.g. from biomass combustion in the electricity value chain) separately from the scopes\"."]
["Survey","European Biogas Association","Other - please specify (required)","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","In ESRS E1, under Disclosure Requirement E1-8, Application Requirements 21 (all Scopes) and 25 (specifically for Scope 3) should be clarified as regards to consistency with other pieces of EU legislation, notably the Renewable Energy Directive (RED). Specifically, AR 21 and AR 25 should recognize explicitly the use of RED-compliant proofs of sustainability (PoS) as valid instruments for emissions accounting from renewable fuel purchase under Scopes 1 and 3.  As highlighted in the European Commission's Explanatory Memorandum accompanying the Simplification Omnibus proposal (February 2025), the ESRS revision must aim to \"clarify provisions that are deemed unclear\" and \"improve consistency with other pieces of EU legislation\". In the European Union, PoS are legally rooted in the RED and are issued within regulated mass-balance systems. The certification framework is supported by national or voluntary schemes recognised by the European Commission, requiring third-party audits, standardised GHG emission accounting, and traceability from feedstock to end-use. Production plants are certified. On this basis, producers can issue PoS that accompany biomethane consignments through the gas infrastructure, where the EU gas grid is legally treated as a single logistical facility. This robust architecture enables companies purchasing certified biomethane (with PoS) to demonstrate measurable and verifiable emissions reductions—even if the physical gas is delivered via shared infrastructure. Explicitly recognising RED-compliant PoS in AR 21 and 25 would: •\tEnhance legal clarity for preparers and auditors; •\tAvoid duplication and conflicting requirements across EU instruments; •\tUphold the EU's ambition to streamline rules and reduce administrative burden; •\tSupport traceable, verifiable decarbonisation pathways for renewable gases."]
["Survey","European Biogas Association","Other - please specify (required)","Belgium","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The European Biogas Association (EBA) welcomes the simplification efforts undertaken by EFRAG in the revision of ESRS E1 and recognises progress made, particularly under Disclosure Requirement E1-8 and related Application Requirements (ARs). Further improvement is necessary under Lever 2 (clarification and consistency with other legislation). In particular, within ESRS E1 Climate Change, Application Requirements 21 and 25 should be revised to explicitly recognise RED-compliant Proofs of Sustainability (PoS) as valid instruments for GHG accounting of renewable gas purchases under Scopes 1 and 3. These instruments are central to the EU's legally binding sustainability framework under the Renewable Energy Directive (RED) and are widely used to demonstrate measurable, auditable GHG reductions within regulated mass-balance systems. Failure to explicitly recognise these instruments leads to unnecessary confusion. Aligning the ESRS with the RED would uphold the objective of reducing administrative burden, increase coherence within EU sustainable finance law. These targeted clarifications would support the practical application of the standard, reduce audit ambiguity, and promote interoperability, while aligning fully with the Commission's mandate to \"clarify provisions that are deemed unclear\" and \"improve consistency with other pieces of EU legislation,\" as stated in the Explanatory Memorandum to the Simplification Omnibus."]
["Survey","European Biogas Association","Other - please specify (required)","Belgium","35.E1-8."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","•\tAR 21 (Applicable to Scopes 1, 2, and 3): RED-compliant Proofs of Sustainability (PoS) should be explicitly recognised as valid instruments for emissions accounting of biomethane purchases across all scopes. This would ensure consistency with EU legislation, particularly the Renewable Energy Directive (Lever 2).  Biogenic emissions: Paragraph (e) of AR 21 requires reporting all biogenic emissions, including CO2, under Scope 1. This is inconsistent with Disclosure Requirement E1-8, paragraph 33 and the GHG Protocol, which treat biogenic CO2 as outside the scopes. This provision should be revised to support interoperability and consistency (Lever 2).  •\tAR 25 (Scope 3): Recommendation: Like AR 21, AR 25 should explicitly recognise RED-compliant PoS for Scope 3 emissions accounting. These instruments are legally grounded and based on EU-regulated certification schemes and mass-balance systems. Clear inclusion would reduce ambiguity (Levers 2 and 4).","E1","Disclosure Requirement E1-8 - Gross Scopes 1, 2, 3 emissions",""]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Amended ESRS 1 lacks a clear definition of impact materiality, comparable to the one included for financial materiality in paragraph 39. To eliminate ambiguity for companies and stakeholders, the definition in the Glossary  needs to be clearly incorporated into the body of ESRS 1. To avoid confusion, this definition should be aligned verbatim with the GRI Standards, which define material topics as those that represent an organization's 'most significant impacts'. This is crucial to ensure clear and consistent application of impact materiality globally. In addition, since the steps for assessing impact materiality are not elaborated on within the ESRS, pointing to GRI 3: Material Topics can provide additional valuable guidance for reporters.  Amended ESRS 1 presumes that investors are the only users of the sustainability statements for decision-making. This is not the case. Other stakeholder groups – such as civil society and policy makers – need to be included, rather than being relegated to being considered as only using this data to achieve an \"understanding\". Otherwise, the principle of double materiality is undermined by the prioritization of financial materiality only. Paragraph 21 (b) must be revised so that information is material when it is necessary for users, including civil society actors, to make informed assessments and decisions about an undertaking's most significant impacts and how it identifies and manages them."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","The new guidance on how to consider remediation, mitigation, and prevention actions in assessing the materiality of negative impacts is now based on a net-impact assessment. This is overly complex, inconsistent with financial materiality (where risks are assessed on a gross basis) and, more importantly, risks excluding severe potential negative impacts from reporting. Net-impact assessments can also vary widely depending on how organizations account for mitigation measures, leading to inconsistent and less comparable reporting.   Assessing impacts on a gross basis means organizations cannot obscure or minimize potential harm simply by pointing to mitigation efforts. Particularly in cases where an impact is highly significant in a specific industry or location, disclosing these impacts and the effective implementation of prevention and mitigation measures provides valuable information to stakeholders. GRI 3: Material Topics provides relevant guidance on how to assess and prioritize impacts for reporting."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","It is important that the NMIG is updated and made available again for public feedback once the Amended ESRS have been finalized. Please refer to pages 29-30 of this Annex for our feedback on the NMIG: https://www.globalreporting.org/media/uo5a3wg0/annex-gri-response-to-public-consultation-on-the-amended-esrs-exposure-drafts.pdf"]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","We have observed a considerable reduction of GRI-aligned data points, both in the cross-cutting and in the topical standards. The proposed amendments should not diminish interoperability with global sustainability reporting standards but rather strengthen it. Considering interoperability with the GRI Standards when deciding which mandatory data points to retain would ensure that any reductions are based on decision-useful impact information, validated through extensive multi-stakeholder consultation. For example, ESRS 2 no longer includes standalone data points on how a company identifies impacts, the involvement with negative impacts, and the provision of remedy, which provided crucial and easily identifiable information about an organization's approach to impacts. Here, reference could be made to GRI 3: Material Topics where this critical information is covered.   In the excel template provided we indicate which of the deleted content we believe should be maintained.  In addition, while we acknowledge the need to simplify reporting by reducing mandatory data points, this cannot come at the expense of meaningful, standardized information on impacts for investors, civil society, and other stakeholders. Although mandatory data points have been significantly reduced, the ESRS continue to require undertakings to report material information on material impacts. However, given that less information under the ESRS will be standardized, there is a risk of reduced reporting quality and comparability. We recommend that paragraph 11 of ESRS 1 includes an explicit reference to the GRI Topic Standards (in addition to GRI Sector Standards), as a reliable source of entity-specific disclosures and likely material topics. This will help ensure that organizations can report standardized information on significant sector-agnostic impacts and topics not covered by the amended ESRS."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.E1.","Comments on deleted datapoints in ESRS E1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.E2.","Comments on deleted datapoints in ESRS E2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.E3.","Comments on deleted datapoints in ESRS E3","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.E4.","Comments on deleted datapoints in ESRS E4","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.E5.","Comments on deleted datapoints in ESRS E5","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.S1","Comments on deleted datapoints in ESRS S1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.S2","Comments on deleted datapoints in ESRS S2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.S3","Comments on deleted datapoints in ESRS S3","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.S4","Comments on deleted datapoints in ESRS S4","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","22.G1","Comments on deleted datapoints in ESRS G1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Please refer to the excel template where we indicate which of the deleted content we believe should be maintained."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We welcome moving data points on total water withdrawals, total water discharges, and the number and nature of the confirmed incidents of corruption from 'may' to 'shall'. This is in line with GRI 303-3-a, GRI 303-4-a and GRI 205-3-a respectively."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","We disagree with the new threshold to report the breakdown of the number of employees by country for the countries in which the undertaking has 50 or more employees and that are the ten largest countries in terms of employee numbers. Similar to the previous threshold, it can obscure material information on where a significant number of employees are located and for understanding the potential impacts of undertakings. We recommend aligning with GRI 2-7-a and require a breakdown of the number of employees by region. In GRI 2-7, a region can refer to a country or other geographic locations, such as a city or a world region. This can provide flexibility to undertakings to report information at country level or by world region or other appropriate level, according to the specific circumstances of each undertaking, but on a complete basis."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Former E4 AR 26 has been deleted as it was considered potentially outdated. We support retaining guidance on what biodiversity and ecosystems-related targets can cover. However, AR 26 in its former form is narrow and focused primarily on quantitative measures of areas or sites. Drawing on the GRI Standards, including GRI 101: Biodiversity 2024 (Disclosure 101-1-c and its guidance), we recommend that the Application Requirements more clearly reflect that biodiversity-related targets should be measurable, time-bound, and linked to the most significant impacts of the undertaking; specify baselines used; indicate how the targets are informed by the Kunming-Montreal Global Biodiversity Framework and science-based approaches such as SBTN; and cover an organization's most significant impacts in direct operations and upstream and downstream the value chain."]
["Survey","Global Reporting Initiative","Standard setting initiative","Netherlands","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","The gender pay gap should be reported by employee category and by significant location of operation, to assess whether there is equal remuneration for work of equal value. GRI recommends replacing S1 44(a) with the adjusted pay gap, disaggregated by employee category for each significant location of operation, in line with GRI 405-1."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","In principle, the BAK welcomes the newly introduced practical regulations for carrying out the materiality analysis. From the BAK's point of view, however, the planned reduction in the granularity of a number of reporting obligations via the materiality analysis will result in a significant loss of transparency and information for the relevant stakeholders.  Furthermore, it is provided that the involvement of stakeholders is required, but no further steps are necessary (AR 10 for para 33). It must be ensured that stakeholders can articulate their demands and that management can derive goals, measures, etc. from them. Only then can the effects on employees, suppliers in the value chain, consumers and the environment be recorded in reporting. This process should be reflected in the report so that stakeholders can understand how the company developed its topics. It is also unclear whether the proposed guidance provides sufficient clarity and transparency as to what level of adequate and proportionate evidence is needed to support the conclusions of the materiality analysis."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I would like to skip this question and provide my feedback in Part 3",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","The BAK welcomes the proposal for an \"executive summary\" at the beginning of the Sustainability Report. However, it must be ensured that it is indeed only \"a summary\" and not the actual report.  The concept of connected information offers a good way to avoid repetition. This leads to better readability and comprehensibility of the report. However, it is essential to provide an overall overview of all references in the report so that stakeholders can look up or be informed.  In addition, if there are too many references, there is a risk that the clarity, transparency and comprehensibility of the reporting will suffer or be restricted.  The BAK is of the opinion that all relevant information should be provided directly in the sustainability report in the management report. If information or information is moved in annexes, the BAK believes that it is essential to ensure that all annexes must also be disclosed and that they can be found clearly and easily in the report.  Furthermore, the question arises for the BAK as to whether these simplifications will not make connectivity to financial reporting more difficult. The BAK therefore requests that appropriate consideration be taken into account so that the sustainability and financial reporting remains coherent in itself. This has always been a goal of the EU Commission and should therefore continue to be observed."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I disagree","From the BAK's point of view, the following points are critically assessed or rejected:  Less mandatory disclosures: The BAK opposes the planned deterioration of the disclosure requirements for ESRS 1 and 2.  Planned changes to mandatory reporting content on voluntary disclosures or the general deletion of the \"may\" regulations: These reductions lead to a significant loss of information for stakeholders and cannot guarantee comprehensible, transparent and understandable reporting. Simplifications should only be carried out if this does not lead to a qualitative impairment of reporting.   The BAK therefore advocates a revision of the ESRS 1 and 2 regulations in accordance with ESRS Set 1.   No metrics are specified in the ESRS S 2-4. Therefore, the BAK proposes that the regulation to disclose relevant, company-specific information should be included directly in these standards. Otherwise, there is the impression that no company-specific information is required for these social standards.   The BAK is against an extension of the \"phasing-in\" regulations."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Unfortunately, the present draft provides for the mandatory guidelines to be downgraded to \"no longer mandatory\". From the BAK's point of view, this is associated with a significant deterioration in sustainability reporting. In addition, it is questionable what effect EFRAG's interpretative guidelines, which are declared non-binding, will have in practice. It can be assumed that they will have a certain binding effect. However, in such important areas of the European economy, this is viewed critically. Direct publications by the European institutions, specifically by the Commission, would be preferable. These would also better support companies in reporting."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","In European sustainability reporting, the ESRS must always be in the foreground. A pure orientation towards the ISSB standards is not advocated. EFRAG has already taken the GRI standards into account very much during the development of ESRS Set 1. This should also be taken into account in the new revision. The newly introduced principle of \"fair presentation\" must ensure in all cases that sufficient transparency and reliability of all essential regulations in reporting is given."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","22.S1","Comments on deleted datapoints in ESRS S1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","The exposure drafts (April 2022) and the EFRAG draft of Set 1 (November 2022) have already seen a significant reduction in disclosure requirements for companies.  The BAK therefore considers it urgently necessary that the draft standards now available are not further shortened or watered down in the further legislative process. This would result in a significant deterioration in the new sustainability reporting.  In its statement of January 2023 on EFRAG's Set 1 published in November 2022, the Federal Chamber of Labour has already critically stated that the scope of the disclosure requirements has been significantly reduced compared to the exposure drafts from the consultation in summer 2022.   It is precisely through the standards that it must be ensured that the information needs of stakeholders who are significantly affected by the entrepreneurial activities and their effects are met. These include, in particular, the requirements of trade unions, works councils and employees for a transparent, comparable mapping of working conditions in the sustainability indicators to be reported and the associated sustainability goals and risks.  From the BAK's point of view, the following points are critically assessed or rejected:  Less mandatory disclosures or shift from mandatory reporting content to voluntary disclosures: The BAK is clearly opposed to the planned deterioration of the mandatory disclosure requirements, especially for ESRS E1 and ESRS S 1. In the CSRD Article 29b, all social information is listed in detail. Therefore, these social aspects in particular should be reflected in the ESRS.  From the BAK's point of view, the planned reduction in the granularity of a number of reporting obligations (e.g. no age groups for S1-8 diversity, no breakdown by gender for S 1-12 training) will result in a significant loss of transparency and information for the relevant stakeholders.   The BAK therefore advocates a resumption of the regulations (for the topic standards) in accordance with the currently applicable Delegated Act on the ESRS."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","The BAK welcomes the mandatory information: - on the Biodiversity Transition Plan E4, - for training of procurement teams (procurement teams are of great importance, especially in connection with the value chain) and - for incidents of corruption/bribery."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","These exceptions provide important information and are therefore justified and appropriate."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","This new principle of \"fair presentation\" is generally welcomed. However, it must not lead to the omission of important topics that are necessary for complete, meaningful, comparable and auditable sustainability reporting under this guise."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The change in the thresholds for reporting the number of persons employed is welcomed, as it provides more information on the number of employees, especially from companies operating in several countries, and this data is also necessary for other social indicators. In addition, there are no additional data points associated with it for the companies obliged to report."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree","These proposed simplifications support companies in reporting on SFDR-related topics. For users, this consolidation makes it easier to find the relevant information. However, the SFDR data points are very helpful and should only be changed selectively."]
["Survey","Chamber of Labour, Austria","Trade union","Austria","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?",null,"-"]
["Survey","Chamber of Labour, Austria","Trade union","Austria","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Please refer to the Excel template for comments on the standards"]
["Survey","Chamber of Labour, Austria","Trade union","Austria","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","Chamber of Labour, Austria","Trade union","Austria","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree",""]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","3A Advisory SARL-S","Consultant (including software vendor)","Luxembourg","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We welcome the proposed amendments to the ESRS which represent a positive step forward. However, we suggest to consider a more flexible approach as regards the double materiality assessment by clarifying that companies should only carry out a full DMA periodically or when there are significant changes in their strategy or business model, and not necessarily on a yearly basis. Companies could instead review internally their DMA every year to determine whether such a reassessment is necessary. The DMA should therefore only be audited when updated periodically. It would also be beneficial to clearly define what constitutes a reassessment to avoid divergent interpretations of this concept by preparers and auditors.  We also support the use of reasonable and supportable information available without undue cost or effort (ESRS 2 paragraph 47 & chapter 7.3), as well as ESRS 1 paragraph 48 on materiality based on the business model and AR 17 on the top-down approach.  It is important to grant undertakings discretion to define the appropriate level of disaggregation whether by topic, business or another relevant area.  We recommend deleting references to sub-sub-topics such as in Appendix A E4 (\"Drivers of biodiversity and ecosystem change (terrestrial and marine habitat change, invasive species)\"). We would like to avoid unnecessary burden and audit pressure."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","We agree with adopting a net approach to assessing potential negative impacts within the Double Materiality Assessment (DMA). This reflects real business practices, where impacts are evaluated after accounting for credible, systematic, and effective prevention and mitigation measures. Industrial companies already invest heavily in regulatory compliance, site-level controls, advanced monitoring systems, and global frameworks (e.g., ISO, OGMP 2.0). These measures are audited, budgeted and continuously improved to reduce risk exposure. A gross-only assessment would inflate disclosures with hypothetical risks that are already effectively managed, creating excessive burden and misrepresenting actual exposure. A net approach ensures disclosures remain decision-useful, rewarding companies for proactive and data-backed mitigation efforts.  However, on the other hand, we caution against the rigidity introduced by the gross vs. net approach in Appendix C. Framing materiality around gross impacts risks turning the exercise into a theoretical checklist, disconnected from sustainability reporting's purpose of accountability, comparability, and faithful representation. Safety topics, for instance, would be reported regardless, as they are business priorities even without annual incidents. By treating all impacts as material, the gross approach risks over-reporting and obscuring meaningful disclosures."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We support the changes proposed since they provide more clarity on how to report the disclosure requirements related to Policies, Actions and Targets. However, we reiterate that EFRAG should explore the possibility of merging disclosure requirements on PATs in the topical standards as these are often implemented together."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We fully support the changes introduced as regards the distinction between mandatory from voluntary datapoints, as it was flagged as one of the main sources of confusion during the preparation of the sustainability statements, also presenting challenges with auditors.  However, further simplification and precision are needed to improve usability and avoid confusion, particularly with auditors.  - Unclear and contradictory terminology should be eliminated. For instance, terms such as \"shall consider\" create ambiguity: \"shall\" implies mandatory action, while \"consider\" suggests discretion. This phrasing leaves room for interpretation and could result in inconsistent application or auditor disputes. - Application requirements (ARs) that use \"may\" should be removed, as \"may\" implies voluntary action, which contradicts the stated objective of eliminating voluntary disclosures. Clear, mandatory language is essential to ensure consistency and enforceability across undertakings."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We strongly support excluding the NMIG from the Delegated Act to ensure it is clearly interpreted as non-mandatory, in order to prevent an unintended increase in reporting burden. The NMIG should remain a helpful reference tool for preparers, not a regulatory requirement. This connects with the need of moving all voluntary and non-mandatory data points into a separate document to improve the clarity of the standards."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We strongly support that disclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21).   What is more, we fully support other relief measures introduced by EFRAG: - included in [DRAFT] ESRS 1 section 5.4 as regards acquisitions and disposal - included in [DRAFT] ESRS 1 paragraph 92 allowing reporting undertakings to exclude joint operations over which they don't have operational control for the calculation of certain environmental metrics.   However, additional alignment with financial reporting (i.e. IFRS 11-Joint arrangements) could be achieved. Following the financial consolidation method would improve the consistency of the information reported by companies.  We would also like to draw attention to confusions and unclarities when reporting confidential information, especially justifying its omission to auditors."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We fully support the relief measures as regards the use of reasonable and supportable information that is available without undue cost or effort as it will significantly reduce the administrative burden on reporting undertakings. We believe this provision should be permanent and not subject to a time limit as proposed by some EFRAG SRB members (as mentioned in paragraph 76 of the [DRAFT] Basis for Conclusions. In the case of large Capital Groups, some information may not be available for a long time, not just a year or two, because it requires a complete remodeling of the current method of data collection.  We particularly support ESRS 1, paragraph 92, which acknowledges the practical limitations of data availability in joint operations where the undertaking lacks operational control. Allowing the exclusion of such operations from environmental metrics is a pragmatic solution that enhances reporting feasibility and avoids duplicative or misleading disclosures.  Similarly, we endorse ESRS 1, paragraph 91, which permits the use of metrics based on a partial scope of calculation. This flexibility is vital in the early years of reporting, when data systems are still evolving. Importantly, the requirement for companies to disclose the scope limitations and outline plans to improve data coverage ensures transparency and demonstrates continuous progress."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","We would like to recommend the wording included in OPTION 2, since it better addresses our concerns on the sensitivity of the information disclosed and on the excessive burden in calculating quantitative disclosures. The issue of anticipated financial impacts is extremely difficult. Advisors themselves don't yet know how to approach the topic, and preparing for the disclosure of such data can take years for large capital groups.  What is more, such flexibility is necessary given the significant legal risks which are particularly acute where disclosures include financial data not reported in official financial statements and not reliably estimable. Such disclosures should fall under the remit of financial boards to ensure consistency with financial reporting requirements.  If disclosure requirements are maintained, they should focus on qualitative information only, providing general indications of the time horizon and type of effects (e.g., financial position, performance, cash flows). Anticipated effects must be consistent with those considered for current financial effects. Crucially, inherent effects should not be required, as these are theoretical, not grounded in reasonable and supportable information, and risk misleading external users."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","It is crucial not to require disclosure 'before considering adaptation/mitigation actions', as this does not reflect how business strategy is defined and adds little value for users. Mitigation measures are typically embedded within corporate strategy, structural in nature, and linked to multiple risks. Attempting to calculate hypothetical monetary amounts before mitigation is both overly complex and unreliable, producing figures that are neither estimable nor dependable. For less technical readers, such disclosures could be misleading, especially since they are not recognized in the financial statements.  We therefore strongly recommend limiting anticipated financial effect disclosures to qualitative information only.  As a suggestion, the IFRS S1 reliefs in § 38 and § 39 should be integrated in the ESRS: 38. An entity need not provide quantitative information about the current or anticipated financial effects of a sustainability-related risk or opportunity if the entity determines that: (a) those effects are not separately identifiable; or (b) the level of measurement uncertainty involved in estimating those effects is so high that the resulting quantitative information would not be useful (see paragraphs 77–82). 39. In addition, an entity need not provide quantitative information about the anticipated financial effects of a sustainability-related risk or opportunity if the entity does not have the skills, capabilities or resources to provide that quantitative information.",null,null,""]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","We fully support the change that the datapoint reduction resulted in the elimination of 7 \"shall\" datapoints described in Basis for Conclusions (BfC) (Chapter 4, Lever 6). Also, we support the changes introduced to enhance interoperability with the ISSB standards, especially the harmonization of the reporting boundary for GHG emissions."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.E1.","Comments on deleted datapoints in ESRS E1","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.E4.","Comments on deleted datapoints in ESRS E4","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.S1","Comments on deleted datapoints in ESRS S1","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.S2","Comments on deleted datapoints in ESRS S2","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.S3","Comments on deleted datapoints in ESRS S3","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.S4","Comments on deleted datapoints in ESRS S4","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.G1","Comments on deleted datapoints in ESRS G1","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","We do not agree on adding new datapoints, especially when these datapoints were assessed as voluntary after a thorough drafting process of the ESRS and should remain as such since their content, and therefore their relevance, have not changed."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","The introduction of new mandatory datapoints contradicts the stated objective of simplifying the standards. Organizations are already facing significant challenges in collecting and reporting the extensive information required under ESRS. Adding further datapoints - such as on microplastics, critical raw materials, or waste - will increase the complexity of the process and burden companies, many of which are still in the early stages of building robust reporting systems.   This challenge is particularly acute in the downstream value chain, where companies have very limited visibility and control over how products are used after leaving their facilities. Obtaining reliable data from customers, distributors, or end-users is in practice extremely complex, and in many cases simply not feasible.   Instead of introducing these requirements as mandatory at this stage, we strongly recommend that such topics are first developed and tested within non-mandatory guidance (NMIG). This would allow companies to experiment and progressively prepare their reporting systems. Imposing new obligations undermines the principle of burden relief and seriously threatens the feasibility of the entire reporting framework, especially for sectors with complex and fragmented value chains."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree"]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","We are concerned that the revised workforce disclosures introduce a level of detail that is not necessarily relevant or decision-useful, particularly for multinational companies. The requirement to disclose employee numbers per country with more than 50 employees may add little value, as in practice these employees may be concentrated in a single region (e.g., Europe) without enhancing the reader's understanding of global workforce distribution. A more representative and meaningful approach would be to return to the previous version of the disclosure, which required companies to report on countries where there are more than 50 employees representing at least 10% of the total workforce. This ensures focus on material geographies while avoiding unnecessary granularity.  We also recommend removing the requirement to disaggregate employees by contract type (permanent, temporary, non-guaranteed). While well-intentioned, this requirement offers limited value to users and creates disproportionate complexity for preparers. Contract categories are defined differently across jurisdictions, leading to inconsistencies and undermining comparability. Moreover, workforce composition often fluctuates throughout the year, particularly in industries with seasonal demand or project-based work, which reduces the reliability of such disclosures."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree"]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","We agree with the deletion of that voluntary datapoint. However, [DRAFT] DR S1-15 still requires the undertaking to disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees. The undertaking must also disclose the annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual).  It is still problematic because a significant amount of the top management's remuneration relies on variable income, which in turn relies on the financial results and statements; this indicator cannot therefore be calculated accurately before the certification of the financial statement, which puts its publication in jeopardy every year.  Also, the preparation of these disclosures is significantly challenging for large capital groups with numerous subsidiaries. This would require having data on the annual salary of each employee of the group, which would have to be collected outside the HR and payroll system. Obtaining such data would be also difficult in the context of the EU data protection law, as it is only available to the employer at subsidiary level."]
["Survey","ORLEN S.A.","Preparer (non-financial preparing a sustainability report)","Poland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"On value chain reporting, we respectfully request that EFRAG consider limiting the scope of the impact materiality assessment to entities with which an undertaking has a direct contractual relationship. For large multinational organizations, value chains are highly complex and global in scope. Tracking and assessing impacts beyond direct contractual partners presents substantial practical, operational, and methodological challenges, particularly given the absence of consistent data availability and supplier transparency. In many cases, undertakings lack the leverage to influence or collect reliable information from actors further down the chain, resulting in disclosures that are burdensome to produce yet incomplete or inaccurate in practice.  Also, it is important that the ESRS are properly translated into other languages by ESG experts in order to minimise errors and interpretational confusion."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","11. DMA simplification → Partially agree Good on clarity/top-down option; risk of under-reporting unless expectations for documentation and stakeholder input are explicit."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","12. \"Gross vs net\" guidance → Agree Assessing potential impacts gross prevents \"we manage it well, so it's immaterial\" logic; keep, but add examples by sector."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","13. Readability & connectivity → Agree Exec summary + appendices help users; insist cross-references to financials and capex pathways."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","14. ESRS2 & topical standards restructure (PAT) → Partially agree Less prescriptive is fine, but don't weaken Policies-Actions-Targets linkage to material IROs; require traceability from IRO → PAT → metrics."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","15. Clarity/accessibility → Agree Clear split mand./non-mand. reduces checklist behaviour."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","16. NMIG role → Agree Keep outside Delegated Act; warn auditors not to treat NMIG as de-facto mandatory."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","17. Burden reliefs overall → Partially agree Useful, but risk of data gaps; tie reliefs to improvement plans and auditable timelines."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","18. Data-quality relief (partial scope) → Partially agree Allow partials with a time-bound ramp-up (e.g., scope ↑ annually) and quantified coverage %; no open-ended use."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","19. Anticipated financial effects → Option 1 Keep quantitative info with guardrails; otherwise investors can't price transition/physical risks."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","20. E1 financial-effects paras 40–42 → Partially agree Simpler, but ensure scenario, time-horizon and balance-sheet/cash-flow channels remain explicit.",null,null,""]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","21. Interoperability with IFRS S1/S2 → Agree Financial-control boundary is a big win; avoid extra reliefs that break alignment."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","22. Datapoint reduction → Partially agree OK if critical GHG, transition plan, and value-chain metrics remain intact; watch loss of decision-useful PAT details."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","23. Six \"may\" → \"shall\" → Agree Targeted upgrades improve clarity."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","24. Four new mandatory DPs → Agree If they close genuine decision-useful gaps."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","25. Fair-presentation emphasis → Agree Supports materiality and reduces boilerplate; provide examples to reduce litigation fear."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","26. FI absolute targets exception → Disagree Need intensity + absolute; intensity alone can mask rising financed emissions."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","27. S1 country thresholds → Agree Top-10 approach is more decision-useful; burden is manageable."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","28. Non-EU adequate wages → Partially agree Align with ILO is good; require which prong used and encourage reputable living-wage datasets earlier in the hierarchy."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","29. SFDR PAI incorporation → Partially agree Avoid duplication; ensure remaining PAIs are fully covered and traceable."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","30. E4 AR26 biodiversity targets → Partially agree Update with SBTN-aligned metrics (pressures, state, response) and area/condition quality."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","31. S1 adjusted gender pay gap deletion → Disagree Keep adjusted gap (by category/country) for management action; unadjusted % alone misleads."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","32. G1 payment practices → Partially agree PAT is fine, but add a simple KPI (e.g., % invoices paid ≤30/60 days) to protect SMEs."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","Simplification helps; ensure guardrails on reliefs, time-bound data-quality improvements, and strong ISSB interoperability."]
["Survey","Birkenstock Group B.V. & Co. KG","Preparer (non-financial preparing a sustainability report)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Why this helps CO₂ in practice:  Better interoperability (ESRS↔ISSB) → lower cost to report once, freeing capacity for actual abatement.  Clear IRO→PAT→Metrics chain → capital shifts to low-carbon options.  Risks: unlimited reliefs or weaker PAT detail → less pressure to decarbonise. Hence the guardrails above."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Chapter 3 is clearer and better organised. The improved definition of materiality of information in Section 3.1, namely the replacement of criterion of \"significance\" with \"understandability\" of impacts provides better guidance and is aligned with the CSRD and international sustainability due diligence instruments. It also clarifies how the materiality of information interacts with (fundamental) qualitative characteristics of information criteria from Chapter 2, and with the rules concerning aggregation and disaggregation of information (e.g. para 52 on \"not obscuring\"). Section 3.5. Practical considerations are particularly helpful to avoid unnecessary complexity in materiality assessment. However, Chapter 3 frequently conflates 'topics' with 'impacts, risks and opportunities' ('IROs'). Para 22 is confusing when it says that information may be presented \"either at the topical level or at [IRO] level\". Such a dichotomy is confusing and incorrect. While topics refer to broad thematic areas, IROs are entity specific. The CSRD, as well as IFRS, TCFD, and TNFD consistently focus on the latter. Overemphasising 'topics' risks leading to generic, boilerplate disclosures that lack relevance and specificity. Chapter 3 would be clearer if it keeps the focus on IROs and plainly explain that depending on their nature and context such IROs may be defined at a general level - often corresponding to topics - and/or that information on their management may be similarly aggregated. This should be clarified also in provisions on entity-specific disclosures in paragraph 23 (and in paragraph 10 in Chapter 1) In Chapter 3.3.2, para 37 fails to mention that the purpose of financial material assessment is to not just to identify materiality information but also determine the material risks and opportunities, as required by the CSRD. In this regard, the risks and opportunities are only mentioned in the middle of para 38, making the text incoherent."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","It is useful that Chapter 3 addresses the question of how prevention, mitigation and remedy of impacts shall be considered in materiality assessment, but the rules could be expressed in a more simple and understandable way.  Para 34 uses a very complicated language to express a simple idea that actual impacts shall be considered as they occurred during the reporting period, and that their ex-post remediation is not relevant. We welcome and stress the importance of the clarification that the potential impacts which require significant ongoing preventative or mitigation efforts shall be considered gross. Without such clarification, it would be in theory be impossible for companies to report on how they manage such issues. In this regard, it would be helpful to refer to the materiality of information filters to provide companies with further guidance on how to distinguish such significant efforts from common practice and compliance measures.  The table provided in Appendix C provides more detailed information, which it would be helpful to integrate directly into the main body to ensure clarity and consistency."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","The proposed changes are meaningful. We would like to bring the attention to para 113, which we find hard to understand:  \"113. If the description of the material impacts, risks and opportunities prepared in accordance with [Draft] Amended ESRS 2 IRO-2 is not presented alongside the respective policies, actions and targets, the undertaking shall make explicit which policies, actions and targets relate to which material impacts, risks, or opportunities, in accordance with paragraph 22.\" It is not clear to us what the reference to para 22 is meant to imply. Para 22 addresses the issue of appropriate aggregation or disaggregation of information on material impacts, risks and opportunities and their management. But it doesn't set any rules regarding the location of such disclosures depending (or not) on the level of aggregation."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","We welcome the removal of the duplications between the cross-cutting and topical standards. We support the emphasis on general disclosure requirements.  Likewise, many PAT provisions in the topical standards had a character of examples or guidances rather than datapoints. Additionally, the preservation of the 5-part and 4-part architecture of the environmental and social standards respectively is welcome and important in providing a structure and language for preparers to navigate the issues, communicate internally with colleagues and organise their disclosures with regard to social issues. The environmental standards similarly provide an architecture that supports this kind of navigation, and which are retained, including with the specific metrics under each of standards E1 to E5. The architecture should be complete and equivalent across the standards However, we have two critical concerns. First, the original DR in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. We welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened. Second, we strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics and the anticipated sectoral standards which would have provided such metrics will not be adopted, shift the expectations for disclosure of metrics for S topics to entity-specific disclosures."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We support the proposed changes. We agree with the removal of 'may disclose' elements, because their status has been causing confusion. However, they do not need to be all removed to NMIG. Where they provide useful examples of disclosures, they could be included directly in the standards as \"examples\". This is particularly the case for the topics for which the reporting practice is evolving, such as Biodiversity and ecosystems. This would make it easier for first-time preparers to understand what kind of information is likely to be relevant and provide a basis for the standardization of metrics. Having to consult another document, such as NMIG, is adding an unnecessary hurdle. The language and therefore understandability of the standards have been considerably improved, however in ESRS 1 especially there is still much to be done in this regard."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The standards are not clear in terms of what the combined effect of the reliefs is and how the reliefs are meant to interact. Interpreting and applying these reliefs independently of each other open doors to abuse and omitting material information, significant differences in reporting practice.  Reporting of metrics is subject to a combination of undue cost and effort and lack of data quality reliefs. But the standards do not put these two reliefs in proper context and do not include any explicit requirement and timeframe for companies to improve the coverage and quality of data. This is exacerbated by the relief which unconditionally allows exclusion of joint operations. If the environmental metrics concerning such operations are material, then the standards should incentivise their eventual disclosure. The undue cost and effort and lack of data quality reliefs already provide sufficient flexibility in this regard. Similarly, there is a lack of coherence among the directions of the reliefs related to financial effects, i.e., information which is essential for understanding of the risks and company's ability to overcome them.  The limitation related to the announced investment plans focuses the disclosures on effects which are easier to assess and therefore quantify, yet the standards also propose reliefs that enable omitting quantitative disclosures. We broadly agree with the relief provided in ESRS 1, para 90, which allows for calculation of metrics exclusion of activities that are not significant drivers of the IROs. However, the application of this option must be clarified for specific environmental and social metrics which are standardised in the ESRS. For instance, the GHG Protocol's completeness principle explicitly warns against misapplication of materiality criteria in this regard. Similarly, for S1 workforce metrics, such as characteristics of the employees and non-employees, such exclusions are not appropriate."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","These combined reliefs should clearly require the undertaking to improve the coverage and quality of the data needed to meet ESRS requirements. For the metrics concerning own operations and/or metrics standardised directly in the ESRS, this should be subject to clear time limitation. For other metrics, improvements over the years should be also explicitly required, subject to undue cost and effort relief."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material. Resigning on this ambition is at odds with the objective of putting sustainability reporting on the same level as financial reporting, the integration of both, and ultimately overcoming the tragedy of horizons. We find Option 1 unnecessarily extensive, and lacking time limitation, but broadly acceptable. We disagree with the assertion made in the question that it \"[d]ifferent from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources \". In this regard, the new proposed ESRS include the undue cost and effort relief which seems to account for such a situation. With respect to Option 2, we don't find it justifiable to go beyond the IFRS relief. One of the most strongly voiced arguments from stakeholders who called for simplification of ESRS was that, as a matter of principle, ESRS must be aligned with the IFRS except where CSRD or other EU legislation require otherwise. Abandonment of this principle seriously undermines prospects of building a global baseline which both the EU and the ISSB support, and which is an important part of building a level playing field for the EU companies."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Reliefs should not go beyond those set in IFRS. Going further would undermine the objective of setting a global baseline for ESG reporting, which is important for achieving a level playing field for EU companies in a global context. The undue cost and effort relief outlined in ESRS 1, para 87-89, is a powerful relief, which addresses virtually all situations where the undertaking may encounter practical obstacles.  Explicit emphasis on fair presentation, combined with the strengthened focus on the use of materiality of information filter, provide companies with an increased flexibility in determining meaningful content of their sustainability statements. It marks a further move away from compliance-based to principle-based approach. However, such changes imply increased responsibility for the undertaking. Implementing further reliefs would undermine this responsibility and open the doors to abuse."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","The number of datapoints in each standard represent the minimum necessary to ensure cohesive disclosure requirements, and consequently basic comparability and quality of the actual disclosures. We have not identified any instance where ESRS would include exorbitant requirements, considered common practice and internationally recognised reporting standards and frameworks such as IFRS, GRI, or TNFD. ESRS are generally more concise and less demanding. Introducing further reductions (while keeping the coverage of all ESG factors as required by the CSRD) would create serious quality gaps between the ESRS disclosures and those based on the standards."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We agree with these changes, noting that the suggested changes do not add a new burden.  This is particularly the case for the water-related metrics. In order to disclose the water consumption, the undertaking already has to calculate withdrawals and discharges, and such calculation and therefore the underlying data is subject to the assurance. Moving these implicit datapoints to the forefront as explicit data points makes the disclosure requirement clearer, compared to the previous ESRS where some of these datapoints were framed as \"may disclosures\". Whether or not these individual datapoints are to be disclosed is correctly subject to materiality of the information filter applied by the undertaking."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We agree with these changes, noting that the suggested changes do not add a new burden.  E2-4 on secondary microplastics is not a new datapoint, as correctly pointed out in the Rationale above. We do not understand why it is included in this question, as such."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","ESRS, being based on the materiality principle, the CSRD requirement to disclose impacts, risks and opportunities and their management, and the general principles of the Accounting Directive, has already been subject to a fair presentation regime. Making it explicit helps to clarify it. It provides companies with clarity on the discretion and judgement, as well as related safeguard, they are expected to exercise when applying the standards."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We recognise the complexity of recalculating absolute values and acknowledge that financial institutions often manage GHG performance using intensity-based approaches. However, the global carbon budget is defined in absolute terms. For this reason, it remains essential that even financial institutions disclose absolute targets to assess how their strategies align with the economy-wide transition to net zero. Absolute targets are relevant for users of sustainability statements and for understanding the real-world climate impact of financed activities. While intensity measures provide insights into efficiency, they can mask rising absolute emissions in growing portfolios or sectors. Absolute values, by contrast, give a clear signal of whether institutions are contributing to the necessary 90–95% global reduction in emissions by 2050, with steep cuts by 2030. Both approaches rely on similar underlying data, and estimation challenges are not unique to the financial sector. Granting an exemption would also undermine fairness in a sector-agnostic standard. Other industries could equally argue for exceptions based on their own difficulties, reducing comparability across sectors. Moreover, absolute financed emissions are already recognised in existing standards and regulations: the SBTi financial sector net-zero standard, the UNEP FI/NZBA recommendations, and EU SFDR all require or encourage absolute emissions disclosure. Exempting banks would risk misalignment and reduce the usefulness of reported data for stakeholders, including asset owners who depend on it for their own disclosures."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The new threshold is simpler and clearer, and therefore easier to apply. It also sets a clear cap. Any potential increase of breakdowns of the disclosed information is negligent in terms of added burden."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","This should be addressed through revisions to para AR 22.  The methodology presents four key problems:  1.\tIt undermines the objective: the methodology for reporting on whether all employees earn an adequate wage should not include an option that is tied to the generally much lower standard of the legal minimum wage 2.\tIt is discriminatory. The disclosure would have companies apply a lower standard to their employees outside of the EU than they apply to those inside the EU. 3.\tIt is complex for companies: The methodology would require companies themselves to assess whether minimum wages in each country align with the ILO's wage-setting principles, and whether living wage benchmarks align with the ILO's principles for estimating living wages. 4.\tIt undermines comparability of reports: If they apply these different standards for reporting on adequate wages depending on the location of employees, the data is not comparable.  Two key changes are therefore needed: •\tThe methodology for reporting on adequate wages should measure actual wages against an adequate/living wage for all employees not only those within the EU. In particular, for employees outside the EU, the methodology should allow employees' actual wages to be measured: o\tagainst the local legal minimum wage only when this is set in line with the ILO principles on estimating living wages; or o\tagainst living wage estimates that are set in line with ILO principles on estimating living wages. •\tCompanies should be able to rely on local legal minimum wages or living wage estimates when the authorities or organisations that set them provide public evidence of their alignment with the ILO principles for estimating living wages. This will avoid companies' having to make this assessment themselves."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","We welcome the fact that multiplication of datapoints was removed. The new, simplified framework makes it easier for companies to report on these SFDR-related matters in a way that corresponds to how their policies are set. For users, this consolidation makes it easier to locate the relevant information."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Measurable targets related to biodiversity and ecosystems shall be set and disclosed according to the guidance and examples given by relevant global frameworks, such as SBTN (Step 3 - Measure, Set & Disclose Targets), TNFD (component P1 and P2 & Annex 5, sector guidance and guidance on Target Setting) & resources by World Economic Forum Nature-Positive Transitions."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","Our proposal is to not include such datapoint, but instead provide a paragraph in the application requirements, explaining that the adjusted pay gap is an important entity-specific information, which is often necessary to contextualise and enable understanding of the information provided by the unadjusted pay gap. Further this AR could remind the undertakings that the unadjusted pay gap needs to be appropriately disaggregated. Unadjusted and adjusted perspectives on pay gap have different purposes. The unadjusted pay gap - appropriately broken down by countries or areas of operations in line with ESRS 1 - provides general context and the information on how the undertaking is affected by systemic drivers of gender inequality. The adjusted pay gap is primarily an entity-specific disclosure. It is particularly relevant for complex companies to better understand where and how the pay gap manifests, and what are the specific drivers of it. There is no one 'standardizable' way to adjust the pay gap calculation. Such adjustments must consider the undertaking's specific context and circumstances and avoid 'overadjusting'. If the calculation controls for every source of difference between males and females in the workforce, then it would obscure the pay gap and its causes. Therefore, including a datapoint - whether mandatory or voluntary - on adjusted pay gap in the standards is problematic, because it is impossible to provide a standardised methodology. On the other hand, for many companies' information on adjusted pay gap is likely to be material, and therefore such information should be provided."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","The removal of paragraph 14 can be easily compensated by adding a reference to SMEs in the description of the topics in ESRS 1, Appendix A, and in ESRS G1, paragraph 4.  The removal of datapoint originally located in para 33(a) concerning average days it takes to pay an invoice, does not seem to be necessary for the reduction of burden. The undertaking would still need to collect this data to be able to meet the other requirements, in particular the calculation of the % of its payment aligned with its standard payment terms (in para 20(a))."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","ESRS 1: We are concerned about the concurrent effect of various reliefs. We are also concerned about the unintended confusion caused by a rather confusing explanation of the relationship between impacts, risks and opportunities on one hand, and sustainability topics on the other."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS 2: We disagree with the downgrading of the transparency on site/assets/activities screening from the level of datapoints in the E standards to an Application Requirement in ESRS 2."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS E1: We do not think that the streamlining of the E1-1 Transition Plan for Climate Change Mitigation added value. If anything, more rather than less details and clarifications are needed. The glossary could retain the definition of net zero targets and related criteria, as use and reporting of such targets is a common practice."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS E2, E3, E5: We welcome the changes made, including the clarification and minor additions to the datapoints in the metrics section. They provide for greater clarity and do not add further reporting burden."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS E2, E3, E5: We welcome the changes made, including the clarification and minor additions to the datapoints in the metrics section. They provide for greater clarity and do not add further reporting burden."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS E4: Given the current state of art in this area, it would be helpful to include more guidance on how to set metrics and how to utilise the other reporting frameworks and standards such as the TCFD. The standard should also clearly require the disclosure of sites in/near biodiversity sensitive areas, rather than limiting it to those determined to be connected to material impacts only."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS E2, E3, E5: We welcome the changes made, including the clarification and minor additions to the datapoints in the metrics section. They provide for greater clarity and do not add further reporting burden."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS S1, S2, S3, S4: We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS S1, S2, S3, S4: We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS S1, S2, S3, S4: We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS S1, S2, S3, S4: We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS G1: We particularly welcome the streamlining and alignment of the structure of this standard with the remainder of the standards"]
["Survey","Jaekel Consulting","Consultant (including software vendor)","Sweden","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","NomoGaia","NGO","United States","35.S1-1."," Do you agree with the amendments of this chapter? ","I agree",null,"S1","Disclosure Requirement S1-1 - Policies related to Own workforce",""]
["Survey","NomoGaia","NGO","United States","35.S1-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","See specific comment on Excel Spreadsheet.","S1","Disclosure Requirement S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy",""]
["Survey","NomoGaia","NGO","United States","35.S1-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","This is one instance where lumping together material risks, implacts and opportunies is not helpful. Disclosure of impact key actions  should be specific and detailed. Human rights risk reporting is universally general and vague.","S1","Disclosure Requirement S1-3 - Actions and Resources related to Own workforce",""]
["Survey","NomoGaia","NGO","United States","35.S2-1."," Do you agree with the amendments of this chapter? ","I agree",null,"S2","Disclosure Requirement S2-1 - Policies related to value chain workers",""]
["Survey","NomoGaia","NGO","United States","35.S2-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","There should be required disclosure on how the undertaking communicates the existance of, and access method to, its human rights grievance mechanisms. Many companies and institution have such mechanisms but they do not sufficiently publicize them to make them know and so used. Also, the UNGP 31 Effectiveness Criteria are good general principles but they do not state criteria that can be used to ensure that a grievance mechanism is effective or porvides effective remedy.","S2","Disclosure Requirement S2-2 - Engagement with value chain workers, existence of channels for value chain workers to raise concerns or needs and approaches to remedy.",""]
["Survey","NomoGaia","NGO","United States","35.S2-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","This is another instance where lumping together risk, impacts and opportunies is counter productive. Key actions taken in respose to negative human rights impacts need to be specifically disclosed as do remedies.","S2","Disclosure Requirement S2-3 - Actions and resources related to value chain workers",""]
["Survey","NomoGaia","NGO","United States","35.S2-4."," Do you agree with the amendments of this chapter? ","I agree",null,"S2","Disclosure Requirement S2-4 - Targets related to value chain workers",""]
["Survey","NomoGaia","NGO","United States","35.S3-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","There should be a required disclosure on how the undertaking makes its human rigths grievance mechanisms know to potential claimants.","S3","Disclosure Requirement S3-1 - Policies related to affected communities",""]
["Survey","NomoGaia","NGO","United States","35.S3-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","If an undertaking takes the position that it has recieved FPIC from an indigenous people it should disclosure that contention and describe the project or actions consented to. This is abolutely key to allow FPIC claims to be publicly addressed.","S3","Disclosure Requirement S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy",""]
["Survey","NomoGaia","NGO","United States","35.S3-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Key actions for human rights impacts need to be specifically describd.","S3","Disclosure Requirement S3-3 - Actions and resources related to affected communities",""]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The proposals encompass the maximum level of possible simplification. Any further simplification would undermine the goals of the ESRS and the EU's wider goals.  We welcome the move away from an approach that is too prescriptive and may result in companies focusing on disclosure compliance rather than risk prevention and mitigation. However, this draft places too much hope on good practice by business, which will result in incomparable data and an uneven playing field. We suggest that a middle ground be sought by providing additional guidance, such as (i) The examples included in the previous version (ii) Guidance for transition plans, which many companies still lack clarity on (iii) Sector-specific approaches with dedicated disclosures or guidance documents, allowing the identification of sector-wide risks and a level playing field between businesses, without overburdening them."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We welcome the move away from an approach that is too prescriptive and may result in companies focusing on disclosure compliance rather than risk prevention and mitigation. However, this draft places too much hope on good practice by business, which will result in incomparable data and an uneven playing field. We suggest that a middle ground be sought by providing additional guidance, such as (i) The examples included in the previous version (ii) Guidance for transition plans, which many companies still lack clarity on (iii) Sector-specific approaches with dedicated disclosures or guidance documents, allowing the identification of sector-wide risks and a level playing field between businesses, without overburdening them."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","While we understand the benefit of a shorter ESRS, we would welcome the retention of the \"May disclose\" reporting points as they can provide a helpful framework for frontrunners who want to go beyond simple compliance. If preferable, these reporting points may be included in an Appendix to the ESRS.  We welcome the move away from an approach that is too prescriptive and may result in companies focusing on disclosure compliance rather than risk prevention and mitigation. However, this draft places too much hope on good practice by business, which will result in incomparable data and an uneven playing field. We suggest that a middle ground be sought by providing additional guidance, such as (i) The examples included in the previous version (ii) Guidance for transition plans, which many companies still lack clarity on (iii) Sector-specific approaches with dedicated disclosures or guidance documents, allowing the identification of sector-wide risks and a level playing field between businesses, without overburdening them."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","The relief on financial effects is concerning. Financial effects are a key principle of financial materiality and are also embedded in the IFRS. While we understand the difficulty in assessing anticipated financial effects, the ESRS is a key opportunity to drive methodological and technical innovation for these assessment. While initial disclosures will be limited, they will be crucial, and data will improve over time. We strongly recommend this relief be removed.  The relief for \"undo cost and effort\" is too generic. It will allow companies to omit critical KPIs and create an uneven playing field. While it is important to reduce the burden, this is already achieved through (i) the materiality process (ii) the reduction in the number of \"shall disclose\" reporting indicators and (iii) the removal of the \"may disclose\" indicators, which are the ones that may be omitted if data collection is deemed too difficult. If further relief is required, we recommend qualifying statements."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","The relief for \"undo cost and effort\" is too generic. It will allow companies to omit critical KPIs and create an uneven playing field. While it is important to reduce the burden, this is already achieved through (i) the materiality process (ii) the reduction in the number of \"shall disclose\" reporting indicators and (iii) the removal of the \"may disclose\" indicators, which are the ones that may be omitted if data collection is deemed too difficult. If further relief is required, we recommend qualifying statements."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","The relief on financial effects is concerning. Financial effects are a key principle of financial materiality and are also embedded in the IFRS. While we understand the difficulty in assessing anticipated financial effects, the ESRS is a key opportunity to drive methodological and technical innovation for these assessment. While initial disclosures will be limited, they will be crucial, and data will improve over time. We strongly recommend this relief be removed.  If the relief is to be retained, we recommend option 1 be prioritised over option 2."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree",null,null,null,""]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","We strongly support the closer alignment with the IFRS which will simplify reporting and allow greater interoperability"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","The disclosure requirement for adequate wages is inadequate as it requires companies to determine whether wages in each context align with ILO wage-setting principles. This process will be burdensome for companies and will not allow fair comparisons. The disclosure should be amended to reference adequate, living or fair wages, benchmarked against available criteria by the ILO or - ideally - developed by the EU Commission.  The percentage of workers who took family-related leave should be reintroduced as part of the work-life balance metric."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","We strongly support the retention of sector-agnostic standards ESRS S3 (Affected communities) which requires \"an explanation of the general approach the undertaking takes to identify and manage any material actual and potential impacts on affected communities in relation to communities' economic, social and cultural rights (for example, adequate housing…)\". With the housing crisis getting increasingly worse across Europe, it's crucial that this reference be retained in the final ESRS."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The disclosure requirement for adequate wages is inadequate as it requires companies to determine whether wages in each context align with ILO wage-setting principles. This process will be burdensome for companies and will not allow fair comparisons. The disclosure should be amended to reference adequate, living or fair wages, benchmarked against available criteria by the ILO or - ideally - developed by the EU Commission."]
["Survey","Institute for Human Rights and Business","NGO","United Kingdom","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","The previously drafted gender pay gap metric is more appropriate and should be included ahead of this revised version"]
["Survey","Save the Children","NGO","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Save the Children believes that it is important that the double materiality approach (DMA) has been maintained in the simplification efforts as well as its alignment with the due diligence steps and international standards. Save the Children also welcomes the definition of affected stakeholders that explicitly includes \"persons in vulnerable situations\" (now AR 10), as children are part of this group. This is in line with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines on Multinational Enterprises for Responsible Business Conduct. Specifically considering children in the DMA will allow companies to identify and assess specific impacts on children that are often severe, but many times remain invisible. Any further simplification would misalign the ESRS with international standards and companies' practice, thus creating different approaches to DMA that would make comparability among sustainability reports challenging."]
["Survey","Save the Children","NGO","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Save the Children agrees that the maintenance of the 4-part structure of the social standards is welcome as impacts, risks and opportunities vary depending on the type of stakeholders. This allows preparers to better understand the issues and communicate them internally and externally. Conversely, in the social topical standards, requirements to further disclose the characteristics of the undertaking's stakeholders, including whether these are persons in vulnerable situations, such as children and young workers, have been deleted (ESRS S1 DR related to ESRS 2 SBM-3, AR 8; ESRS S2 DR related to ESRS 2 SBM-3, AR 8; ESRS S3 DR related to ESRS 2 SBM-3, 9(a); ESRS S4,  DR related to ESRS 2 SBM-3, 10(a) ). This amendment ignores that impacts on different stakeholders requires different action and that a company's strategy and business model might affect stakeholders differently, such as children. For example, as exemplified by the UN Committee on the Rights of the Child in its General Comment no 25 on \"children's rights in the digital environment\": \"The digital environment includes businesses that rely financially on processing personal data to target revenue-generating or paid-for content, and such processes intentionally and unintentionally affect the digital experiences of children. Many of those processes involve multiple commercial partners, creating a supply chain of commercial activity and the processing of personal data that may result in violations or abuses of children's rights, including through advertising design features that anticipate and guide a child's actions towards more extreme content, automated notifications that can interrupt sleep or the use of a child's personal information or location to target potentially harmful commercially driven content\". Absence of this information from sustainability reports would impede investors from assessing the undertaking's sustainability performance. Save the Children recommends re-instating these DR and AR in the social standards."]
["Survey","Save the Children","NGO","Sweden","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","Save the Children","NGO","Sweden","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Save the Children suggests that in ESRS S1 new para 2: the UN Convention on the Rights of the Child should be added to align with the text of the CSRD (Recital 49). ESRS S1 14(b): information on whether child labour is widespread or systematic in the context where companies operates and the operations that are at significant risk of incidents of child labour is important information to help companies identify and manage their material impacts. Such information is necessary already at the DMA stage. This information is also relevant for investors and users to assess the performance of the undertaking.  ESRS S1 new para 34(d): parental leave is an equally important datapoint to achieve both gender equality and children's rights. Evidence shows that longer periods of paid parental leave (for both mothers and fathers) improve child health and lower poverty.  ESRS S1 old para. 93(b): the datapoint on the percentage of entitled employees that took family related leave with a gender breakdown is essential to understand the real effectiveness of companies' policies as it can indicate whether there are barriers to employees in taking advantage of existing work-life balance policies.  ESRS S1-1 old AR13: the description of existing policies on child labour is essential information for both investors and other users. In addition, when it comes to children's rights this is something that most companies already disclose.  ESRS S1 DR related to ESRS 2 SBM-3, AR 8; ESRS S2 DR related to ESRS 2 SBM-3, AR 8; ESRS S3 DR related to ESRS 2 SBM-3, 9(a); ESRS S4, DR related to ESRS 2 SBM-3, 10(a): see answer to question 14."]
["Survey","Save the Children","NGO","Sweden","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Save the Children welcomes the fact that there is no change to the definition of child labour in the Glossary as it is aligns with the international child rights legal framework (UN Convention on the Rights of the Child and ILO Conventions)."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","We note grave concerns with the amended text as double materiality has been weakened in both definition and operationalization. In consequence, clarity regarding definition and approach to DMA are compromised. For example, deletion of §28 ESRS 1 appears dubiously justified under the claim that this streamlines content and simplifies understandings of the DMA, when in fact proposed changes (reformulation under §22) reduce the clarity of the DMA process.  The CSRD/ESRS rests on the DM principle. The amended text must therefore explicitly specify that prominence is given to the double materiality as a general filter, and that requirements are subject to it. However, the text now refers only to materiality, introducing ambiguity and room for misinterpretation. We see serval risks with this amendment: Ambiguity will likely mean that companies use financial materiality as a general filter, in which case many environmental impacts not deemed financially material will be excluded.  Different undertakings will (or have the flexibility to) identify different material impacts, even if they operate in the same sectors. This necessarily undermines reliability and comparability of said information for investors. Underreporting will create potentially large gaps in impact information, undermining assessments of risks and opportunities. How large a gap in impact information will remain unknow as impact reporting is not guided by any scientific benchmark. This will create large uncertainties regarding the representativeness and usefulness of the information generated by ESRS.  Above listed issues will undermine the decision-usefulness of the information for investors, as reliable risk estimates fundamentally depend on credible impact assessments.  We argue for a DMA process underpinned by scientific guidance, and that the EC solicit the expertise of the scientific community to develop this. Our organization stands ready to accept."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Guidance is valuable, but the complexity by which environmental impacts translate to risks introduces the probability of underreporting systemic risks because of a lack of understanding about the causal connections between the two.  SRC recommends erring on the side of gross impact disclosure, especially for environmental impacts where systemic risks remain despite mitigation (e.g. biodiversity loss, climate tipping points). We recognize the tension/ debate in this regard and strongly recommend that EFRAG collaborate with scientific knowledge partners such as SRC and iDiv and others to ensure that streamlining does not come at the expense of relevance, reliability, and verifiability.  This should be done in revision process and the aforementioned institutions express their willingness to help with field testing.  Subjective materiality remains an issue for this ESRS 1 guidance (see Q11). We therefore emphasize that environmental impacts are inherently linked to human rights issues and must therefore be prioritized in a way that advances severity considerations first and foremost. For this, scientific knowledge and grounding for materiality assessments is crucial.  Remediation impacts must be assessed in accordance with scientific knowledge and praxis, and valuation guidance will be needed to translate these impacts into disclosures. We believe such guidance should be informed in dialogue with scientific knowledge partners in the revision process."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","In line with our response to Q 11, we are concerned that the simplification and amendment of text has introduced an ambiguity in the materiality filter that is to guide all subsequent reporting requirements for a reporting organization. As noted under Q11, the effect of this ambiguity is likely to be a reduced usefulness of the information for all users of the disclosures, as it will undermine comparability, increase uncertainty surrounding the reliability and representativeness of the information, which in turn affects its reliability for further risk assessments."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","We recognize the tension between costs and preserving the transparency needed to achieve the objectives of the EU Green Deal. However, we have grave concerns that the current amendments and the introduced relief for \"undue cost or effort\", including for the calculation of metrics, will encourage perpetual underreporting.  For some of the environmental impact data in the DR it is natural that the initial implementation and subsequent internal reorganization to gather such information may result in costs. As with any initial investment, this cost would be expected to abate over the subsequent years. Introducing this relief poses a high risk that companies who do not currently have appropriate data structures in place to gather the information will deem the cost too high and hence refrain from reporting, referring to this relief. This would be a highly negative outcome of the amendment. We also find the introduced relief for lack of data quality of metrics (ESRS 1 §91) to be problematic as this will undermine the relevance and usefulness of the disclosures. For both undue costs and data quality relief we recommend a structured and time limited approach, where a transition period can be granted for gradual implementation, but where after a given time period the relief shall be phased out. This would reduce the likelihood of perpetual underreporting or poor quality disclosures."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We strongly support these exceptions related to ESRS E 3 and 4."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","Faithful presentation requires that disclosed information be complete, neutral, and accurate. As noted under Q11, we see a real and tangible risk that unless the materiality filter to be used is clarified as being a double materiality filter, there is a high risk that fair presentation will be compromised as environmental and social impacts that are not deemed to be immediately financially material are likely to be excluded. This will be only a partial presentation of information and will negatively affect the usefulness of said information for both primary users and other users.  We call for a clarification of fair presentation in relation to double materiality and for an involvement of the scientific community in anchoring the Qualitative Characteristics of Information for environmental impacts in science. This would ensure that the fundamental characteristics relating to relevance, completeness, neutrality, accuracy, verifiability and comparability would be satisfied. Furthermore, we suggest that guidance be developed together with scientists to support the DMA process as well as other critical decisions, such as 'appropriate level of aggregation' (e.g. ESRS 1 §51), which if left up to the discretion of individual reporting organizations will likely undermine the principle of fair presentation."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We strongly maintain that intensity targets, while capturing efficiency, are highly likely to mask rising emission levels.  Allowing investors to continue without absolute targets de-emphasizes pressure on them to not just ensure their portfolio companies have targets but also timebound milestones for significant reductions. Cumulative assessments are needed to ensure alignment with EU targets and global climate goals, and for this we need absolute targets.  We recognize that growth of companies with relatively low carbon intensity measures will result in a growing absolute carbon footprint of that asset. If this growth means that other more carbon intense companies are removed from the market this should not affect the overall carbon footprint of an investor's portfolio and would thus be a non-issue for investors with an absolute target. However, if the entire market grows and companies with a higher carbon intensity remain on the market, supported by investors and without any timebound targets to reduce absolute (and relative) emissions, this will result in failure to meet the net zero targets and transgression of critical environmental boundaries."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Biodiversity loss is driven by environmental pressures and IPBES has identified 5 key direct drivers/pressures. In corporate reporting it is therefore important to make a distinction between the drivers of biodiversity loss/change and biodiversity outcomes. We suggest that ESRS adopt an approach where targets for biodiversity are quantitative, location-specific, and anchored in key drivers of biodiversity change identified by IPBES. Targets should include: •\tGHG emissions •\tLand(/sea) use change •\tFreshwater use •\tPollution •\tInvasive species  All targets should specify a baseline year, a target year, and a geographical scope—preferably one target for each operational location. If quantitative targets are unavailable, undertakings should be required to provide a plan for developing such targets. This approach would ensure that biodiversity targets are linked to the underlying drivers of biodiversity loss and not to convoluted biodiversity metrics, such as biodiversity footprints. Such tools will not offer a consistent and comparable measure even for the same undertaking over time as the underlying models and characterization factors change as science evolves. Furthermore, to output an accurate biodiversity metric footprinting tools require location specific data on environmental pressure. Used with revenue data they return output measures that do not satisfy the qualitative characteristics of Information as stated in Appendix B or ESRS 1. An approach focused on targets for drivers of biodiversity loss would also further strengthen the alignment of ESRS with the Global Biodiversity Framework. However, we do note that the current structure of the topical standards makes these targets awkward, since the key pressures driving biodiversity loss are dispersed across different standards (see response to Q33). Despite this, these biodiversity-related targets would provide measurable and actionable information that is essential for businesses to mitigate biodiversity risk and improve their sustainability strategy."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","We feel compelled to comment on the overall structure of the ESRS in relation to biodiversity. Biodiversity loss is driven by environmental pressures. In corporate reporting it is therefore important to make a distinction between the drivers of biodiversity loss/change and biodiversity outcomes. We note a somewhat awkward structure of the ESRS, where E1-3 provide information on three key drivers of biodiversity change identified by IPBES (climate, water and pollutants), but E4 asks for information on biodiversity outcomes. The remaining two key drivers of biodiversity (land/sea use and invasive species) are 'hidden' as a DR under different topical standards. land/sea use change DR appear under E1 and E4 and invasive species appears as a sub-topic within E4 but is only a DR if biodiversity is deemed material.  Combined with the issues identified in relation to DM (see response to Q11) this structure risks exclusion or underreporting of information about corporate pressures representing these two drivers of biodiversity loss which are essential for scientifically grounded assessments of biodiversity impacts. Such assessments are generally modelled since biodiversity outcomes most often cannot be measured directly without significant costs. Biodiversity impact models do, however, require information on the key environmental pressures and their location. In its current form, the essential information on environmental pressures driving biodiversity loss are scattered across 4 different topical sandards, and each must pass through the materiality filter before becoming a required datapoint."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","We believe the issues with the structure will result in many companies not disclosing information about some or all of their environmental pressures (and locations) in a way that makes reliable and science-based biodiversity impact assessments possible. We emphasize that collection/disclosure of environmentally material environmental pressures by companies could and should be combined with empirical measures of biodiversity impacts as these methods develop. ESRS should therefore encode this flexibility to report empirical measures of biodiversity (e.g. eDNA) but this should be complementary, and not replace mandated disclosures about environmental pressure. We note that definition of 'near' to Biodiversity Sensitive Areas is now included in the new ARs, but given the importance for this definition in guiding DR E4-2, we find the definition lacking in clarity. Who determines the capacity for negative impact and based on what? Who evaluates the quality and relevant characteristics of a buffer zone, and based on what? For the AR8 §20 to have meaningful effect we recommend that scientifically anchored guidance be developed to guide the determination of 'near' in the context of BSAs.  We note that DPs that covered resilience and strategy have been removed from the topical standard and replaced with a new focus on Transition Plans, where this type information should be provided instead. However, Transition Plans shall only be disclosed if they are already publicly available from the organization, leading to there being no obligation or urgency to develop such a plan. In short, it becomes very easy to opt out of disclosing information on strategy even if it is highly material."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","We note and strongly support that the new DR E4-5 centralizes the obligation to report location for material biodiversity impacts. However, the disaggregation principle must be accompanied by science-based guidance regarding what can be considered an appropriate level of aggregation/disaggregation (see feedback on development of scientific guidance Q11). In DPs focusing on disclosure of materials or products, a new writing has been added that \"key products/materials\" should be disclosed. This new focus on 'key' introduces room for undertakings to themselves decide what constitutes a key material to report, leading to underreporting of environmentally harmful products or materials if they are not considered significant enough by the reporting organization."]
["Survey","Stockholm Resilience Centre","Academia","Sweden","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Guidance is valuable, but the complexity by which environmental impacts translate to risks introduces the probability of underreporting systemic risks because of a lack of understanding about the causal connections between the two.  Simplification must not dilute the essential message: companies operate within ecological limits. ESRS should remain a tool to effectively connect and align corporate reporting with the broader EU and international framework of economic and environmental instruments, including the Green Deal, Paris Agreement, and CBD/GBF. The structured nature of this consultation questionnaire means we have not been able to provide detailed suggestions for changes but we strongly urge EFRAG to include scientific knowledge partners in the revision process."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We believe that the proposed changes to the double materiality assessment (DMA) represent a significant step forward in terms of clarity and simplification, but do not fully strike the right balance between simplification and robustness. On the positive side, the clarification of the limits to be considered in identifying impacts, risks, and opportunities (IROs), the elimination of redundancies, and the integration of inputs from risk management processes all represent progress. These measures increase consistency, reduce reporting costs, and enable a more effective link between financial and impact materiality. The option to report only sub-topics when they are materially relevant is also a practical improvement, as it avoids unnecessary obligations and may encourage companies outside the CSRD's scope to engage in this exercise as a useful tool. However, the revisions raise important risks. The generalized openness to the top-down approach, without clear criteria for its application, may lead large entities to adopt less in-depth methodologies, weakening comparability and limiting the usefulness of DMA as a strategic tool for sustainability management. Similarly, the possibility of conducting only qualitative assessments, without differentiating time horizons or breaking down severity into scale, scope, and irremediable nature, reduces objectivity and undermines credibility. This excessive simplification creates ambiguities that can be exploited to minimize transparency. The clarification that positive impacts cannot be confused with legal or regulatory obligations is a valuable development, as is the reinforcement of the need to disclose ongoing remediation actions and their results when a negative impact is material. These measures strengthen transparency and alignment with international best practices, reducing risks of greenwashing.In summary,we recognize important progress, but argue that simplification should not compromise the methodological integrity of DMA.Greater clarity is needed on when and for whom the top-down approach is justified, as well as minimum safeguards for rigor in qualitative analysis."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","We acknowledge that the new guidance on how to consider remediation, mitigation, and prevention actions in assessing the materiality of negative impacts represents a valuable effort to address one of the most debated implementation issues — the so-called \"gross vs. net\" dilemma. In principle, clarification enhances transparency and comparability by establishing when to consider the effect of actions and by requiring disclosure of ongoing remediation efforts. It also prevents companies from disregarding highly relevant impacts simply because they operate in sectors with strong preventive measures already in place. However, we share some of the concerns raised within EFRAG and by practitioners. The provisions are complex and create risks of inconsistent application across entities. In particular, the rule that potential impacts must be assessed on a \"gross\" basis when significant ongoing actions are required can lead to excessive reporting and confusion. At the same time, allowing entities to take credit for actions implemented before the occurrence of an actual impact introduces subjectivity and may reduce comparability between entities. The balance between recognizing proactive risk management and avoiding under-reporting of material issues remains fragile. We agree with the clarification that remediation actions implemented in the same reporting period should not reduce the severity assessment of actual negative impacts. This reinforces accountability and ensures that companies remain transparent about incidents, regardless of the corrective measures taken afterward. Similarly, the clarification that positive impacts cannot be offset against negative ones is a relevant safeguard to ensure transparency and avoid misrepresentation. The guidance provided is a step forward in addressing a long-standing gap, but it still requires clarification and stronger safeguards to ensure consistent application. Clearer thresholds, illustrative examples, and minimum criteria for when gross versus net assessment applies would be essential to ensure that the process generates useful and comparable information across sectors."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","The proposed amendments to improve readability, conciseness, and connectivity of ESRS sustainability statements represent a positive step forward. The introduction of clearer structures, harmonized reporting logic, and the option to include executive summaries all help to reduce complexity and make disclosures more user-friendly. These changes address legitimate concerns that reports under the original ESRS risked becoming excessively lengthy and difficult for stakeholders to navigate. However, the flexibility in structuring and the strong focus on conciseness may open the door for entities to exclude relevant information under the justification of simplification. The shift to more selective disclosures, while valuable to avoid immaterial detail, creates a risk of underreporting. Connectivity with financial reporting was enhanced through closer alignment with IFRS S1/S2, which is a positive development. But it should not come at the cost of reducing the richness of the information. For instance, anticipated financial effects (Option 2) limited to qualitative disclosures would severely weaken the link between sustainability and financial information. In summary, while we support the direction of improved usability and connectivity, the amendments need clearer safeguards to ensure that conciseness does not undermine transparency. The standards should ensure that the undertakings continue to provide a comprehensive and balanced picture of its actual impacts, risks and opportunities."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We recognize that the proposed restructuring of ESRS 2 and the topical standards addresses some of the key concerns raised in the first reporting cycle. By consolidating general disclosure requirements (policies, actions, targets, and metrics) into ESRS 2 and removing duplications from topical standards, the amendments simplify the architecture, reduce preparation effort, and improve usability, while contributing also to a less repetitive content. This creates clearer reporting logic and better connectivity across disclosures, which is consistent with feedback from preparers and advisory firms. That said, we do not consider that the amendments fully strike the right balance. Without clear safeguards, there is a real risk that entities will report selectively, omitting material information that is critical for stakeholders. The simplification effort should not undermine the ESRS ambition to provide comprehensive, decision-useful and comparable sustainability information. For instance, a company with suppliers in over 30 countries, including several with high risk of forced or child labor, might choose to disclose information only for the 'top 10' countries, being that this is now the criteria. As a result, serious human rights issues in smaller markets could be left unreported, even if they are critical for stakeholders to assess."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We acknowledge that the amendments significantly improve the clarity and accessibility of the ESRS. Simplified language, harmonized structures across standards, and the introduction of illustrative guidance contribute to making the standards more user-friendly, particularly for first-time reporters. These changes directly address concerns raised during the first reporting cycle about complexity and technical jargon."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","The introduction of the Non-Mandatory Illustrative Guidance (NMIG) represents a positive step toward supporting companies, especially those with limited experience in sustainability reporting, in the implementation of the ESRS. However, its non-binding nature raises questions about its practical effectiveness, consistency of application, and alignment with the CSRD's objectives. The NMIG provides practical examples, templates, and interpretative support that can help companies understand how to apply complex disclosure requirements, particularly in areas such as double materiality, value chain boundaries, and environmental targets. It is especially helpful for undertakings who are reporting for the first-time, who may lack internal expertise or resources to interpret the standards on their own. It can also promote convergence in reporting practices across sectors and jurisdictions, improving comparability and auditability. Being non-mandatory, companies may choose to ignore or selectively apply the guidance, leading to inconsistencies in how disclosures are prepared and interpreted. The lack of formal status may also weaken its authority in regulatory or enforcement contexts, especially if national regulators interpret the ESRS differently. Additionally, there is a clear risk that auditors and assurance providers may not treat the NMIG as a reference point, being that it is non-biding, which could then create gaps between preparers and verifiers. To enhance the usefulness and clarity of the NMIG, we recommend that EFRAG: • Clarify the expected use of the NMIG in the context of assurance and supervisory review. • Consider elevating certain parts of the NMIG to mandatory application guidance, especially where consistent interpretation is critical (e.g., materiality assessment, value chain scope). • Ensure that the NMIG is regularly updated to reflect evolving best practices, sector-specific needs, and alignment with international frameworks (e.g., ISSB, GRI, TNFD)."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The amendments introducing new burden reliefs respond to a legitimate concern raised by many preparers, especially first-time reporters and smaller entities: the cost and effort of gathering and validating data across complex value chains. Allowing the use of reasonable and supportable information without undue cost or effort and permitting estimates or partial coverage when data is not fully available are practical measures that will reduce pressure and make implementation more feasible. The transitional reliefs and the flexibility in scope adjustments following acquisitions and disposals are also pragmatic and welcome. On the other hand, we are concerned that the reliefs, as currently drafted, may create too much discretion and risk undermining transparency. While burden reduction is important, it must not compromise the credibility and comparability of disclosures. For instance, allowing entities to omit parts of their value chain due to data limitations could result in material blind spots, particularly in sectors with high upstream or downstream impacts. Without clear guidance and disclosure obligations about the scope of estimates, users may find it difficult to assess the reliability of the reported information. We also note that while the reliefs are designed to align with ISSB's IFRS S1 and S2, the balance is not fully achieved. In certain cases, the ESRS reliefs appear broader, which could reduce interoperability. Investors and other stakeholders expect consistency between the European and global frameworks, and any perception of \"lowering the bar\" in ESRS may weaken confidence in the comparability of sustainability reporting."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The relief was necessary to make implementation feasible, but it must be framed as either a temporary option or be better explained. Companies should demonstrate progress year-on-year in improving data quality, ensuring that the relief does not become a permanent justification for incomplete reporting. In situations where data quality on metrics is limited this relief addresses a real challenge for many undertakings, particularly smaller entities or first-time reporters. The flexibility to use reasonable and supportable information available without undue cost or effort reflects practical realities of data collection across complex value chains. It also aligns ESRS more closely with ISSB's IFRS S1 and S2, which recognize the need for proportionality in early implementation. This should reduce reporting costs and provide a more realistic path to full compliance over time. However, if companies systematically claim data quality limitations, the credibility and comparability of sustainability disclosures may be undermined. Stakeholders expect transparency about how data gaps are handled, and relief cannot become an excuse for omitting material information."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We strongly support Option 1 as the most balanced approach to anticipated financial effects. It maintains the obligation to disclose quantitative information wherever possible, while providing relief in cases where measurement is impracticable or where uncertainty is so high that figures would not be meaningful. This is consistent with the treatment in IFRS S1 and S2, ensuring greater interoperability between ESRS and global standards. It also has the merit of clarifying conditions for relief, which in our view, provides sufficient flexibility to reduce burden while maintaining the credibility and comparability of reports. It acknowledges the challenges undertakings face, especially in early years, but still reinforces the principle that anticipated financial effects are fundamental to connectivity between sustainability and financial reporting. Option 2 would downgrade disclosures to a purely qualitative basis, leaving quantitative information entirely voluntary. This would represent a step backwards in sustainability reporting, especially in areas such as climate change, biodiversity, or pollution, where quantitative disclosures are on their way to became critical to investor decision-making."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","The amended paragraphs 40, 41, and 42 of ESRS E1 represent a clear effort to simplify disclosure requirements on anticipated financial effects of climate-related risks and opportunities. This simplification aligns with the broader goal of reducing the reporting burden, particularly for companies with limited resources or technical capacity. While the amendments improve clarity and alignment with IFRS S2, they may not fully meet the needs of users who require detailed and decision-useful information to assess climate-related financial risks and opportunities. The revised structure is more concise and readable, which facilitates implementation and may improve consistency across companies. The inclusion of a methodology disclosure requirement (paragraph 40(e)) enhances transparency and helps users understand how figures were calculated. Furthermore, alignment with IFRS S2 and the expectations of financial institutions supports interoperability and comparability in capital markets. However, the removal of detailed breakdowns, such as disaggregation by acute versus chronic risks, energy-efficiency classes, and expected liabilities, reduces the granularity of information available to users. The omission of scenario analysis references, previously linked to resilience assessments, also weakens the connection between strategic climate planning and financial disclosures. Moreover, the potential financial benefits from climate-related opportunities, previously addressed in paragraph 69, are no longer explicitly covered. This reduces visibility into how companies intend to capitalize on the transition to a low-carbon economy.While simplification may reduce reporting effort,it risks undermining the usefulness of disclosures for investors, analysts, and other stakeholders who need to understand the financial materiality of climate risks across time horizons, the strategic positioning of companies regarding climate opportunities, and the resilience of business models under different scenarios. To strike a better balance, we recommend that EFRAG reintroduce selected elements from the previous version, such as scenario analysis references and opportunity-related disclosures, and develop NMIG examples to guide companies in quantifying anticipated financial effects.",null,null,""]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","There is a need for caution when considering whether the balance is fully achieved. While simplification has been delivered in the ESRS, some elements diverge from ISSB treatment and may cause confusion. For example, the option of purely qualitative disclosures for anticipated financial effects (Option 2) is not aligned with IFRS S1/S2, which expect quantitative information whenever possible. Allowing Option 2 would reduce comparability and undermine interoperability at precisely the point where convergence is most needed. Similarly, the broader reliefs introduced in ESRS risk creating a perception that European reporting is less rigorous than the ISSB baseline, which could damage the credibility of EU disclosures in global markets. However, one of the key strengths of the Amended ESRS is the clear effort to improve interoperability with the ISSB's IFRS S1 and S2. This alignment is critical for preparers operating internationally, who would otherwise face duplication and inconsistencies when reporting under both frameworks. The closer convergence on materiality (decision-useful information for users), the reinforcement of anticipated financial effects disclosures, and the harmonized structure around governance, strategy, risk management, and metrics/targets are positive steps."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","The deletion of voluntary \"may disclose\" datapoints improve usability and are likely to reduce costs. This simplification also increases focus, avoiding long reports filled with immaterial or redundant information, which stakeholders often found difficult to navigate. However, we are fully aware that there are risks of weakening the comprehensiveness of sustainability reporting in the EU, simplification should not come at the expense of transparency. In particular, steps must be taken to ensure that the remaining datapoints continue to capture the information that is necessary to fulfil the objectives of the EU Green Deal, especially in relation to climate, biodiversity, and social equity. In conclusion, while the reduction in datapoints is an important step towards proportionality, entities should be encouraged to disclose beyond the minimum when information is material, and EFRAG should closely monitor whether critical information gaps emerge under the amended framework."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We agree that the six datapoints identified are appropriately moved from voluntary (\"may\") to mandatory (\"shall\"), as they represent indicators that are decision-useful and good to ensure transparency."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","The rationale behind introducing these four additional mandatory datapoints seems reasonable, as they address areas of high stakeholder relevance and align ESRS with ongoing EU policy developments."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","Explicitly requiring undertakings to adopt the principle of fair presentation when preparing ESRS sustainability statements is an important clarification. This step strengthens the materiality filter by shifting the emphasis away from a purely compliance- and checklist-driven approach, towards one that prioritizes the faithful representation of material impacts, risks, and opportunities. Reducing the likelihood of excessive or immaterial information being reported, improving the relevance of disclosures for stakeholders. This amendment also enhances alignment with international standards. The concept of fair presentation is already embedded in IFRS Accounting Standards, ensuring conceptual consistency and interoperability. At the same time, adopting fair presentation introduces a necessary balance with simplification. One of the risks of the Amended ESRS is that over-simplification could create ambiguities and encourage companies to reduce reporting to the bare minimum. The fair presentation principle provides a safeguard. In conclusion, this amendment is both necessary and beneficial. It reinforces the purpose of the ESRS as more than a compliance exercise, ensuring that disclosures remain meaningful."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We do not support the exemption of financial institutions from reporting absolute GHG emission reduction targets. While intensity targets (e.g., emissions per unit of financing or investment) can provide useful insights into portfolio decarbonization pathways, they are insufficient on their own to convey the full scale of financed emissions and their alignment with global climate goals. There is a need to have information on both intensity and absolute figures to properly assess whether financial institutions are contributing to the EU Green Deal's objective of climate neutrality. We acknowledge the challenges faced by financial institutions in setting and achieving absolute reduction targets, given the reliance on client and investee data. However, this complexity does not justify exemption. There could be a way to put in place a phased-in approach with transitional reliefs, allowing institutions time to strengthen methodologies and data coverage. Exempting financial institutions from disclosing absolute GHG reduction targets would create a major gap in transparency and comparability, weakening both ESRS credibility and alignment with global standards."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","Under the previous ESRS, the requirement was clear: disclose for all countries where the undertaking employs 50 or more employees. This approach struck a fair balance between proportionality and decision-usefulness. It ensured that information was reported for all countries where there was a significant enough workforce to raise meaningful sustainability considerations, without being overly burdensome for entities with only very small presences globally. By limiting reporting to the \"top 10 countries by workforce,\" the amendment risks excluding precisely those jurisdictions where social risks may be most acute, for example, countries with weaker labor protections, higher human rights risks, or systemic gender pay gaps. Fewer employees in such countries may still present material risks or impacts for both the company and affected stakeholders. Investors and regulators will lose visibility over these exposures, reducing the effectiveness for risk assessment. The argument of burden relief is not compelling. Once employee data is collected for workforce management, disclosing country-level information for all countries above the 50-employee threshold does not represent an unreasonable effort, especially considering the importance of these disclosures. We are in disagreement with the proposed amendment. The original threshold of 50 employees per country should be maintained, without a \"top 10\" limitation."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","There is value in clarifying the methodology for calculating adequate wages in non-EU countries. The hierarchy now proposed provides a clearer and more consistent framework for the undertakings. This reduces ambiguity, enhances comparability, and strengthens alignment with international human rights and labor standards. While the clarification is positive, practical guidance and safeguards will be necessary to ensure that entities apply the hierarchy in good faith and with sufficient rigor. For example, disclosure of the source, methodology, and assumptions used to determine adequate wages should be explicitly required. Without this, the datapoint risks becoming a minimal compliance exercise rather than a meaningful contribution to assessing social impacts in global operations. In conclusion, while we welcome clarification and agree with the direction of the amendment, we believe additional safeguards are required."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","I generally agree with the way the SFDR Principal Adverse Impacts (PAIs) have been incorporated into the Amended ESRS, because the approach delivers clear benefits in terms of regulatory coherence, interoperability and usability for financial market participants. By embedding SFDR datapoints directly into the ESRS architecture, undertakings can prepare one dataset that serves multiple reporting regimes (CSRD/ESRS, SFDR, EU Climate Benchmarks, and Pillar 3). This reduces duplication, provides clarity to investors subject to SFDR, and enhances consistency across the EU sustainable finance framework. As a suggestion for improvement, it would be very useful if each Disclosure Requirement (DR) explicitly included a reference indicating when a datapoint is linked to the SFDR. This would allow companies to immediately recognise that the information they are providing also fulfils an SFDR obligation, without having to consult a separate table or appendix. Such a direct reference within each DR would significantly improve usability and efficiency for preparers."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","EFRAG should review AR 26 in the Amended ESRS E4. While the original and now deleted AR 26 may have reflected approaches considered \"outdated,\" it provided valuable methodological guidance for companies, particularly those in biodiversity-intensive sectors such as agriculture, forestry, infrastructure, and extractives, on how to define and disclose measurable biodiversity targets. Even non-traditional sectors (e.g., tourism, retail, real estate) are increasingly expected to address biodiversity impacts and dependencies. These sectors would benefit from practical examples such as habitat restoration (including urban habitats), nature-based solutions, or biodiversity-inclusive procurement practices. Moreover, the recommendations included in AR 26 were aligned with international frameworks, including the Kunming-Montreal Global Biodiversity Framework (Target 2 on restoration, Target 3 on conservation, Target 8 on minimizing impacts, and Target 15 on corporate disclosure), as well as guidance from the Taskforce on Nature-related Financial Disclosures (TNFD) and the Science-Based Targets for Nature (SBTN). The current AR on biodiversity targets (AR 17) appropriately emphasizes the importance of free, prior, and informed consent of local and Indigenous communities. However, it does not fully replace the practical function of AR 26, which offered concrete examples of how to express biodiversity-related targets in measurable terms. The absence of such examples may hinder companies' ability to operationalize biodiversity commitments, especially in sectors where biodiversity is not yet fully integrated into risk and impact management. Therefore, we recommend that EFRAG reintegrate a revised AR 26 that: • Retains examples such as the size and location of protected or restored areas, number of projects with improved ecological integrity, and recreated habitats; • Expands scope to include biodiversity investments, engagement with the value chain to reassess dependencies and impacts, and integration into procurement or land-use planning. Such guidance would support companies in setting material, sector-relevant, and actionable targets, while maintaining alignment with evolving global frameworks."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","While there is a need to acknowledge that simplification and burden reduction are important objectives of the Amended ESRS, removing this datapoint risks weakening transparency in an area that is central to social equity, fairness, and the EU's gender equality agenda. The unadjusted pay gap provides an important but limited insight, as it only measures average differences in pay between men and women without accounting for structural factors such as role, seniority, working hours, or contract type. The adjusted pay gap, by contrast, reflects whether employees performing comparable work receive equal pay. It is therefore a more accurate indicator of potential gender-based discrimination and of the effectiveness of company policies on equal pay and career progression. The adjusted gap is widely recognized as a best practice metric by investors, regulators, and civil society. Deleting it from ESRS may undermine the relevance of disclosures for users seeking to assess companies' progress on diversity, equity, and inclusion. Moreover, many undertakings calculate and disclose adjusted pay gaps, either voluntarily or in response to regulatory requirements in certain jurisdictions. It is recommended to reinstate the adjusted gender pay gap as a datapoint, to ensure that ESRS remain aligned with EU policy priorities on gender equality. Previously, this datapoint was voluntary, which allowed flexibility for entities with lower maturity while still encouraging leading companies to report. It could and should remain voluntary, but removing the option altogether is reductive."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","No, the current replacement and formulation of disclosure requirements G1-2 and G1-6 are not sufficient to meet the CSRD's objectives regarding SME protection. The previous G1-2 explicitly required companies to disclose policies to prevent late payments to SMEs and approaches to supplier relationships, including social and environmental criteria. This offered a clear mechanism to assess procurement practices and their impacts on SMEs. In the amended version, references to SMEs were removed, and the requirement reduced to a general statement on supplier relationships, mainly covering corruption and bribery. While aligned with simplification, this weakens visibility of SME-specific practices, particularly payment behavior and fair treatment. Companies may omit SME engagement altogether, reducing transparency and accountability. Similarly, the previous G1-6 required disclosure of average payment times, standard terms by supplier category (including SMEs), legal proceedings related to late payments, and contextual information on impacts. The amended version retains only two elements: standard payment terms (including SMEs) and number of legal proceedings. This shifts focus from impact to performance, eliminating requirements to explain how payment practices affect SMEs or to disclose improvement strategies. Such omissions undermine incentives for fairer practices, despite the CSRD's explicit aim of supporting SMEs. The removal of SME-specific disclosures limits stakeholders' ability to assess how companies contribute to or mitigate SME vulnerability, particularly in sectors where SMEs are structurally dependent on large buyers and where late payments have severe economic consequences. To align with CSRD objectives, we recommend that EFRAG: • Reintroduce SME-specific elements in G1-2 on payment policies and impact assessment; • Ensure G1-6 requires reporting on both performance (e.g., days to pay) and strategies to improve practices; • Include qualitative disclosures on SME engagement, such as support, capacity building, and fair contracting, within G1-2."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The Amended ESRS represents a meaningful attempt to simplify reporting while still aligning with the EU Green Deal, albeit the balance might not be fully achieved. On the positive side, consolidation of requirements, clearer wording, and the reduction of immaterial datapoints will reduce reporting fatigue and may help companies focus their disclosures on the most material impacts, risks, and opportunities. This is aligned with the Green Deal's objective of steering resources towards the sustainability issues that matter most, with the principle of fair presentation acting as a safeguard, discouraging box-ticking reporting and reinforcing the link between sustainability performance and the EU's ambitions. We support burden reliefs and proportionality, but simplification should not create loopholes that weaken transparency on systemic risks. The broadened acceptance of purely qualitative DMA assessments, reduced disaggregation requirements, and the possibility to omit parts of the value chain under \"undue cost or effort\" could lead to the omission of information critical for tracking progress on climate neutrality, biodiversity protection, and social justice. Similarly, the proposal to exempt financial institutions from absolute GHG reduction targets and to limit workforce disclosures to the \"top 10 countries\" would leave significant blind spots in areas that the Green Deal explicitly aims to address, sustainable finance, and safeguarding labor rights and fair working condition."]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","GRACE - Empresas Responsáveis","Business association (other than association of financial institution)","Portugal","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","DGB","Trade union","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The materiality analysis is the cornerstone of sustainability reporting, as sustainability matters are reportable only if material impacts, risks, or opportunities are identified through this process. It is reassuring and important that double materiality has been preserved, ensuring a thorough approach to sustainability reporting. The principle of double materiality must always be upheld and must not be weakened by any simplification or dilution of the regulation. We support including stakeholder engagement and recognizing employees and their representatives as key stakeholders, as suggested in the new draft. However, their involvement should not only be \"central\" but \"mandatory\" in the DMA process. It must also be added in the draft that employee representatives must participate in all key steps of the materiality analysis process.  Employee representatives need to be involved in all stages of the materiality analysis, as they directly represent the interests of the workforce and possess unique insights into the everyday operations and challenges faced by employees. The amended ESRS 1 AR 11 no longer includes the explanation on stakeholder involvement in the materiality assessment process. Specifically, the previous standard emphasized that: \"Engagement with affected stakeholders is central to the undertaking's ongoing due diligence process (see chapter 4 Due diligence) and sustainability materiality assessment. This in-cludes processes to identify and assess actual and potential negative impacts, which then inform the assessment of material impacts for sustainability reporting.\" This clarification from section 3.1 of the old standard must be reinstated. Otherwise, there is a risk that employee representatives will not be properly involved in these processes and will have no real influence."]
["Survey","DGB","Trade union","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","The draft suggests that when determining material impacts, only gross risks are considered, and existing mitigation measures are not taken into account. We consider it important that companies report not just their net impacts but also their gross impacts, and the proposed text maintains this principle. For this reason, we support the draft."]
["Survey","DGB","Trade union","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","Many explanations and examples, including guidance on calculations, have been removed. While this reduces the overall scope and complexity of the ESRS, it increases the need for external examples and support. Moreover, no prescribed structure of reporting is provided (e.g., general disclosures, environment, social, governance), leaving content organization to the company. This poses a risk to transparency and may make it difficult for users to locate the information they need."]
["Survey","DGB","Trade union","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The elimination of duplicate requirements through the reassignment between general requirements (ESRS 2) and topic-specific standards significantly reduces the number of reporting points.  However, it is unacceptable that the draft ESRS weaken stakeholder engagement by remov-ing essential reporting requirements on the involvement of employee representatives and other stakeholders. In particular, the deletion of reporting on strategic and business model changes in response to stakeholder views eliminates information that is crucial for transpar-ency and accountability. Equally concerning is the removal of provisions detailing how companies engage with their own employees and employee representatives about significant actual and potential positive or negative impacts, and how the perspectives of the workforce are reflected in decision-making processes. Unlike the old standards, the draft no longer specifies: •\twhether engagement takes place directly with employees or through their representa-tives, •\tat which stage(s) the engagement occurs, the type and frequency of such engage-ment, and •\tthe role and highest-ranking position within the company responsible for ensuring that this dialogue happens and that its results are integrated into company practices. Leaving reporting on these critical processes optional undermines meaningful participation. Without clear and mandatory disclosure requirements, there is a high risk that employees and their representatives will not be adequately involved."]
["Survey","DGB","Trade union","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Many of the 'may' (voluntary) data points should not be removed. Voluntary disclosures on working conditions for employees without collective agreements, for example, are important because they concern a particularly vulnerable group."]
["Survey","DGB","Trade union","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","-\tThe NMIG contains important explanations that were moved from the standards into the NMIG for the purpose of streamlining the standards. In our view, this does not represent a real improvement for users, since the NMIG, while not formally part of the standards, will in practice likely be treated as implementation guidelines. For this reason, and against the background of the stated goal of \"burden reduction,\" the essential and indispensable content of the NMIG should either be reintegrated into the respective standards or the NMIG should formally become part of the standards."]
["Survey","DGB","Trade union","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","The clause on \"undue cost or effort\" lacks sufficient clarity and leaves companies with too much discretion. Similarly, limiting the use of data in value chain reporting weakens transparency, as direct data is indispensable. In addition, the exemption for operations not deemed \"significant drivers of IROs\" creates excessive flexibility and weakens the reliability of reporting. The relief measures, in their current form, extend beyond what is reasonable and risk undermining the balance between feasibility and transparency."]
["Survey","DGB","Trade union","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Estimating financial effects is essential for integrating sustainability into strategy, planning, and risk management, and for determining financial materiality. Reporting these effects is key to aligning sustainability and financial reporting under the EU's double materiality approach. Companies must remain required to assess financial impacts to provide investors with reliable data and to support sound business planning."]
["Survey","DGB","Trade union","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","DGB","Trade union","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","The reduction in both mandatory and voluntary data points far exceeds a reasonable balance between reporting effort and transparency. The deletion of the S-1 data points should be re-versed. It affects the following disclosures: •\tBreakdown of the company's age structure •\tInformation on non-employees (except for their total number), as no further data is provided (e.g., deletion of disclosures on working conditions, fair remuneration, career development discussions, deaths due to illness) •\tInformation on pension payments (social protection) •\tBreakdown by gender (e.g., employees without guaranteed working hours, persons with disabilities, career development discussions, training and skills development indi-cators) •\tGender pay gap, adjusted by employee category or country/segment •\tData point 'complaints filed with the OECD National Contact Point' •\tVoluntary disclosures on working conditions for employees without collective agree-ments. As part of the updated standards, several data points that were previously mandatory have now become voluntary. However, certain data points should remain mandatory, including participation in performance and career development, average training hours with a gender breakdown, parental leave uptake, and annual total remuneration adjusted for purchasing power differences. The reporting structure has been simplified to consist solely of topics and subtopics, which is acceptable as long as former sub-subtopics are fully integrated into their respective subtop-ics. While data points for S2 correspond to those of S1, those related to water and sanitation have been removed. These data points should be reinstated, as they are critical factors in the value chain outside of Europe."]
["Survey","DGB","Trade union","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","Adding a datapoint on training of the procurement team is needed to support the implementation of human rights in the supply chain. The addition of a datapoint on confirmed incidents of bribery is needed to improve transparency on the effectiveness of bribery/corruption policies and measures."]
["Survey","DGB","Trade union","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","Regarding fair presentation and regardless of the chosen approach - top-down or bottom-up - the result of the materiality analysis needs to be accurate, transparent, and free from distortion. The standards must ensure that any simplifications in the materiality analysis - such as the chosen approach or the omission of the consideration of time horizons or severity dimensions - do not result in incomplete or inadequate assessments. This requirement and the associated obligations should be emphasized much more strongly by the standards and clearly expressed."]
["Survey","DGB","Trade union","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","We very much welcome the improvements in country-specific reporting on employment. Reporting will now apply to the ten countries with the largest number of employees, with a threshold of 50 or more employees - instead of the previous requirement for countries repre-senting 10 % of the total workforce. For these \"Top 10\" countries, disclosures on employment numbers, collective bargaining coverage, and social dialogue are now mandatory. Shifting to a \"Top 10\" country approach is a clear step forward, as it ensures that reporting captures a larger and more representative portion of the workforce. Under the previous 10 % threshold, country-level disclosures often reflected only a small fraction of employees, leav-ing gaps in understanding the real impacts. Expanding coverage to the largest 10 countries provides more meaningful insights into how collective bargaining and social dialogue are ap-plied across different regions."]
["Survey","DGB","Trade union","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","An analysis of the first year ESRS reports shows that most companies are simply reporting that they pay minimum wages, whereas the intention (as outlined in the ESRS Basis for Conclusions) is that companies should be enabled to disclose commitments to paying a wage \"sufficient to support themselves and their families in dignity\" as well as the extent to which they do this. This shows that the methodology for non-EU countries needs to be changed. Furthermore, the new ILO agreement on a methodology for living wages needs to be taken into account. While the proposed new methodology takes a step forward in both regards, two key changes are needed:  •\tThe methodology for reporting on 'adequate wages' should measure actual wages against an adequate/living wage for all employees, not only those within the EU. In particular, for employees outside the EU, the methodology should allow employees' actual wages to be measured: o\tA) against the local legal minimum wage only when this is set in line with the ILO principles on estimating living wages; or o\tB) against living wage estimates that are set in line with ILO principles on estimating living wages. •\tCompanies should be able to rely on local legal minimum wages or living wage estimates when the authorities or organisations that set them provide public evidence of their alignment with the ILO principles for estimating living wages.  Furthermore, the transitional provision for the EU needs to be reinstated, as not all Member States have transposed the Adequate Minimum Wage Directive."]
["Survey","DGB","Trade union","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","The unadjusted gender pay gap should be kept as mandatory, since the methodology for calculating it is clear. The adjusted pay gap figure as voluntary, since the methodology for calculating the adjusted figure is not standardized."]
["Survey","DGB","Trade union","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","DGB","Trade union","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","DGB","Trade union","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","S1 and S2: Regarding the social standards, we are opposed to the removal of key data points and the shift of previously mandatory data points to voluntary. We are concerned that the elimination of many worker-related data points will result in unspecific disclosures, providing less insight into impacts, risks, and opportunities. The reduction in specificity and granularity diminishes the usefulness of the reporting for understanding the real effects on different employee groups. At the same time, we fully support the improvements in country-specific reporting, particularly for disclosures on employment numbers, collective bargaining coverage, and social dialogue. We appreciate the clarification that, when a company applies ESRS S1, the following disclosures must always be reported: S1-5: Characteristics of the company's employees S1-6: Characteristics of the company's non-employee workers S1-16: Discrimination and other human rights violations. In addition, the draft now introduces reporting on all human rights incidents, rather than only \"serious\" cases. This represents a very positive improvement."]
["Survey","DGB","Trade union","Germany","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","DGB","Trade union","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"In conclusion, the draft ESRS weaken stakeholder engagement by removing previously mandatory provisions. Specifically, it eliminates reporting on strategic and business model changes in response to stakeholder views, as well as requirements on how companies engage with employees and their representatives—covering who is consulted, when and how often, and which senior role is responsible. Turning these obligations into optional disclosures undermines transparency, accountability, and meaningful workforce participation. The scope of the definition of \"own workforce\" should be broadened to explicitly include franchise workers. On a positive note, we welcome the clarification in the draft that companies may voluntarily include information on non-material topics.  In addition, the draft now includes explicit references to Article 19a(5) and Recital 52 of the CSRD, requiring management to inform and consult employee representatives and, where relevant, share their feedback with governing bodies. It also clarifies reporting on how boards are informed about the views and interests of key stakeholders, including employee representatives. This marks a notable step forward in transparency and stakeholder engagement and represents a significant enhancement in reporting clarity."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The weakening of requirements for value chain reporting in ESRS E2–E5 is particularly concerning. It would significantly reduce the decision-usefulness of disclosures. Many companies' most severe environmental impacts occur in their value chains, not their direct operations, so the current draft risks obscuring the majority of these companies' ecological footprint.  Company disclosures regarding their value chain are already lagging far behind those for own operations. For example, WBA's Nature Benchmark shows that while 43% of assessed companies demonstrate evidence of reducing plastic use and waste in their own operations, only 7% and 17% respectively do so for upstream and downstream activities. Omitting value-chain metrics risks: - further reducing comparability and usefulness of disclosures for report-users, - creating uneven burden across sectors (with those with higher direct impacts disproportionately affected), and - undermining necessary collaboration along value chains to address systemic challenges.  This approach would also diverge from best practice established by the TNFD, which requires disclosure of asset and activity locations across both operations and value chains. Flexibility on phased timelines may be justified, but it must not prevent companies from beginning their disclosure journey.  We recommend reinstating robust value-chain disclosure requirements across ESRS E2, E3 and E4, with practical guidance to support implementation."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E2; E3; E4; E5; S3","The removal of metric examples from ESRS E4 has created a significant gap, as companies often need support and guidance in identifying appropriate metrics to use. This runs the risk of reducing comparability and consistency, as well as making the process more complex and opaque for companies. This gap could be addressed by providing clearer references to well-established sources—such as those developed by the Science-Based Target Network (SBTN), the Nature Positive initiative, and the Taskforce on Nature-related Financial Disclosures (TNFD). The current draft does not adequately address the social–environment nexus. Many companies struggle to assess and report on how environmental impacts at specific sites (e.g. on water, biodiversity, or pollution) affect local communities. Providing illustrative examples in the NMIG for S3 would help companies understand how to disclose in these integrated cases. This would improve decision-usefulness for stakeholders while also encouraging companies to address interconnected environmental and social risks."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We recognise the need for burden reliefs, but we are concerned that some of the proposed amendments risk undermining the transparency needed to achieve the objectives of the EU Green Deal. In particular, the removal of the systematic preference for direct data in value chain metrics (ESRS 1, Paragraph 91) significantly weakens disclosure.  Value-chain impacts are often where the most severe environmental harms occur, especially in relation to pollution, water, and biodiversity. Allowing companies to rely on estimates without clear safeguards risks reducing comparability and decision-usefulness, and creates disincentives for companies to invest in building robust data systems.  Similarly, the weakening of location-specific disclosures poses a major gap. Actual impacts are inherently site-dependent, and aggregated reporting obscures the ecosystems and communities most affected. For example, our Nature Benchmark shows that while nearly half of companies disclose where they operate, only 10% report on whether those sites are near areas of biodiversity importance, and less than 3% have management plans for such sites. Without site-level information, investors and stakeholders cannot meaningfully assess risks or dependencies.  While flexibility may be needed in early implementation, such reliefs should be clearly temporary and accompanied by guidance that encourages companies to progressively expand coverage and improve data quality and specificity over time. Otherwise, these reliefs risk entrenching current disclosure gaps rather than helping companies overcome them."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","World Benchmarking Alliance","NGO","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We agree with Option 1. Quantitative disclosures on anticipated financial effects are essential for comparability, decision-usefulness, and ensuring credibility of sustainability reporting. Allowing companies to omit quantitative disclosures entirely (Option 2) risks reducing disclosures to high-level narratives that provide little insight to investors, regulators, or civil society.  At the same time, reliefs must be carefully defined. Broad or indefinite reliefs create the risk that companies avoid reporting meaningful information on anticipated financial effects, particularly outside climate. To maintain integrity, these reliefs should be explicitly temporary and subject to clear disclosure of the reasons for omission, along with a timeline for when full coverage will be achieved. Without such safeguards, companies could indefinitely rely on these reliefs, undermining the objectives of the ESRS and comparability across companies.  Maintaining quantitative disclosure as the baseline, while allowing targeted reliefs where methodologies are immature or uncertainty is exceptionally high, strikes the right balance between transparency and feasibility. This approach will incentivise companies and financial institutions to develop more robust methodologies over time, while ensuring that stakeholders continue to receive meaningful, decision-useful information."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","World Benchmarking Alliance","NGO","Netherlands","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","World Benchmarking Alliance","NGO","Netherlands","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Absolute targets are essential to understand an undertaking's true progress on climate. Intensity targets capture efficiency but can mask rising emissions if business activity expands. Complex estimates are not unique to financial institutions. They are common across sectors, and granting an exemption would undermine comparability and create an unlevel playing field.  We also strongly support retaining ESRS E1-1 and keeping financial institutions fully in scope. Climate mitigation transition plans are vital to Europe's net-zero shift, acting as credible blueprints that provide a pathway for real-world change and investment. While all transition plans matter, those from financial institutions (FIs) are pivotal: real-economy companies cannot implement their own transition plans without financing, and the EU's transition will succeed or fail depending on the financial sector's willingness to provide \"transition finance.\"  Evidence shows the current requirements are already driving systemic change. WBA's Financial System Benchmark finds that while only a small share of global FIs currently disclose viable transition plans, more than 70% of these are European institutions – directly reflecting the impact of ESRS requirements. Removing or weakening these requirements would undermine this progress and threaten Europe's wider transition.  The sector is also prepared and supportive. Many European FIs have invested in the skills needed to produce credible transition plans and are now aligning with voluntary frameworks such as the SBTi. These plans are increasingly being extended to cover nature and social issues, laying the foundation for holistic sustainability strategies.  For these reasons, we urge EFRAG to retain ESRS E1-1, maintain absolute target requirements for FIs, and ensure simplification does not compromise Europe's transition to a sustainable economy."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","WBA strongly supports retaining ESRS E1-1 and maintaining mandatory transition plan disclosures for financial institutions:   1. FI transition plans drive systemic change. Without FI transition plans, and the commitments to transition finance contained within them, European companies will not be able to finance their own transitions. Since their introduction, the current requirements have helped put the foundations in place for this to happen - our Financial System Benchmark shows that while only a small share of global FIs currently disclose viable transition plans, over 70% of these are European institutions, reflecting the impact of the ESRS requirements. However, removing or weakening the requirements would undermine this progress and threaten the wider economy's transition.   2. The sector is prepared and supportive. Many European FIs now not only comply with ESRS E1-1 but, having invested in the skills needed to produce transition plans, are now using the model to identify and realise financing opportunities. FIs are also increasingly aligning with voluntary frameworks, including SBTi methodologies, demonstrating that the sector can both meet mandatory requirements and go beyond these. The sector has now upskilled to the point where it can not only meet the requirements, but utilise them for economic gain - removing the requirement would undermine this capability.    3. FIs are now using transition plans to take the next step. FIs within scope of CSRD are now extending their transition planning expertise to integrate social and broader sustainability considerations, creating the foundation for holistic ESG strategies helping them progress on multiple fronts. For example, many FIs are developing transition plans focused on nature, using ESRS E1-1 as a model. Weakening ESRS E1-1 would risk dismantling this additional momentum."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The revised methodology for non-EU adequate wages entrenches global disparities, weakening comparability. We recommend a global adequate/living wage benchmark. Removal of family leave datapoint also reduces gender equality insights."]
["Survey","World Benchmarking Alliance","NGO","Netherlands","35.E4-5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","We are concerned that the amended text of E4-5 (para. 21 and AR 9–11) removes the illustrative metric examples. While companies are still required to report biodiversity metrics, the absence of concrete examples significantly reduces clarity, comparability, and consistency. The broad categories in AR 9 and the high-level guidance in AR 10–11 are useful but insufficient on their own, leaving undertakings with limited direction on which indicators are credible and decision-useful.  We recommend reinstating references to well-established sources of biodiversity metrics, such as the Science-Based Targets Network (SBTN), the Taskforce on Nature-related Financial Disclosures (TNFD), and the Nature Positive Initiative. Providing clear links to these frameworks would help companies select appropriate metrics, strengthen comparability across reports, and improve alignment with global nature-related disclosure standards.","E4","Disclosure Requirement E4-5 - Metrics related to biodiversity and ecosystems change",""]
["Survey","YIT Corporation","Business association (other than association of financial institution)","Finland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Subject: Feedback on ESRS Exposure Drafts – Suggestions for Further Simplification  Dear EFRAG Team,  Thank you for the opportunity to provide feedback on the revised ESRS standards currently under public consultation. We appreciate the efforts made to streamline the standards and reduce the reporting burden. However, we believe there is still room for further simplification to enhance clarity and usability for reporting entities.  For example, we would like to propose the following suggestions:  1.\tRemove Application Requirements (AR) Sections The Application Requirements (AR) sections, while intended to provide guidance, often add complexity and length to the standards. We suggest integrating the relevant content from AR sections directly into the Disclosure Requirements (DRs) text so that separate AR sections exist anymore. This would make the standards more concise and easier to follow without losing essential guidance.  2.\tReduce and Clarify References The current drafts contain numerous references to other standards, frameworks, and documents. While cross-referencing is useful, excessive and unclear references can hinder comprehension. We recommend reducing the number of references and ensuring that any remaining ones are clearly explained within the text, ideally with brief contextual summaries.  3.\tSimplify the Double Materiality Assessment (DMA) The DMA process remains overly complex, particularly with the expectation of scoring or quantifying impacts. We propose a simplified approach where companies identify which ESRS topics are material for company from both impact and financial perspectives and provide a clear rationale for their assessment. Eliminating the need for scoring would make the process more accessible and reduce subjectivity.  We hope these suggestions contribute to the ongoing improvement of the ESRS framework and support its successful implementation across diverse reporting entities.  Yours sincerely, For and on behalf of YIT Oyj Tommi Kokkonen"]
["Survey","LG Energy Solution Wrocław Sp. z o.o. ","Preparer (non-financial preparing a sustainability report)","South Korea","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We positively assess the proposed solution. Based on our own experience, we know how difficult it is to obtain reliable and accurate data, which is why we appreciate EFRAG's position allowing non-disclosure of information when its collection is either impossible or entails excessive costs. However, we would like to highlight that it will be up to the auditor to determine whether a company had valid grounds for not disclosing certain data and whether it made sufficient efforts to obtain it. Based on market experience, we are concerned that some companies may overuse this provision, while others may hesitate to apply it at all. This could affect audit outcomes. We therefore recommend that data points which may result in disproportionate effort be reclassified by EFRAG as non-mandatory. This would help ensure that companies are not solely responsible for making complex judgments—especially in cases where auditors might question the validity of use of 'undue cost or effort' principle. We are strongly convinced that EFRAG is the appropriate body to make these decisions. Additionally, we do not support the decision to exclude ESRS E1-6 from this relief (paragraph 91 ESRS 1). Calculating Scope 3 emissions is particularly challenging, as reliable data is often difficult to obtain. In our view, allowing partial disclosures in this area would be both practical and justified."]
["Survey","LG Energy Solution Wrocław Sp. z o.o. ","Preparer (non-financial preparing a sustainability report)","South Korea","22.S2","Comments on deleted datapoints in ESRS S2","I disagree","As previously noted, we appreciate the efforts made to reduce the overall volume of the ESRS. However, we wish to point out that the number of required disclosures remains substantial—particularly within the Environmental section (E), which continues to be disproportionately extensive compared to other areas. It is also important to highlight that many of the required disclosures are multidimensional, with a single indicator often relying on multiple data sources. Moreover, the removal of certain data points does not necessarily translate into a reduction in workload—for instance, the deletion of the 'total GHG emissions' [ESRS E1-6] item does not alleviate the underlying reporting effort."]
["Survey","LG Energy Solution Wrocław Sp. z o.o. ","Preparer (non-financial preparing a sustainability report)","South Korea","22.G1","Comments on deleted datapoints in ESRS G1","I disagree","As previously noted, we appreciate the efforts made to reduce the overall volume of the ESRS. However, we wish to point out that the number of required disclosures remains substantial—particularly within the Environmental section (E), which continues to be disproportionately extensive compared to other areas. It is also important to highlight that many of the required disclosures are multidimensional, with a single indicator often relying on multiple data sources. Moreover, the removal of certain data points does not necessarily translate into a reduction in workload—for instance, the deletion of the 'total GHG emissions' [ESRS E1-6] item does not alleviate the underlying reporting effort."]
["Survey","OTP Bank","Bank","Hungary","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","If in sectors with strict regulations on a given topic, the primary goal should be to meet and comply with those standards. However, if the topic is material, it should still be reported. The reporting should clearly reflect that the regulatory framework covers the relevant actions, and that the objective is to fulfill those requirements. This ensures that the principle of materiality is respected, and that important topics are not omitted from the report simply due to high regulatory compliance."]
["Survey","OTP Bank","Bank","Hungary","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","OTP Bank","Bank","Hungary","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Institutional Investors Group on Climate Change (IIGCC)","NGO","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","IIGCC partially agrees that the proposed amendments provide an appropriate level of flexibility and should help to reduce overall reporting burdens by allowing for effective summarisation of key information and cross-referencing to other parts of the report.   While we welcome improvements in readability and structure, we do not support any weaking of the connectivity between the narrative report and financial statements, which could have highly detrimental impacts on investor decision-making.  The proposal to make cross-references to financial statements optional ('may cross-refer') rather than mandatory is concerning. From an investor perspective, connectivity between sustainability reports and financial statements is a fundamental requirement for assessing how material climate risks and opportunities impact financial position and performance.  Investors need clear linkages between narrative sustainability disclosures and underlying financial statement assumptions to make informed capital allocation decisions. Without this connectivity, it will be extremely challenging for the market to meaningfully assess the financial impacts of sustainability factors.  We recommend maintaining stronger emphasis on mandatory connectivity between sustainability and financial reporting to preserve the decision-usefulness as these are material disclosure rather than voluntary communication."]
["Survey","Institutional Investors Group on Climate Change (IIGCC)","NGO","United Kingdom","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We have concerns about both options presented, but in the interest of securing quantitative disclosure, our preference would be Option 1. Our strong preference however would be for EFRAG to retain both quantitative and qualitative disclosures relating to anticipated financial effects with significantly stricter criteria for reliefs. These disclosures are critical for preparers to incorporate sustainability factors into their business strategy and financial planning, and for users looking to understand how climate change is expected to impact the bottom line. The disclosure of material climate information is already required under existing IFRS accounting standards used in the EU.. The IASB's educational materials, recent illustrative examples and ISSB's works demonstrate that quantitative disclosure of anticipated financial effects is not only feasible but required when material.   We support the rationale for the proposed omission of reliefs based on a lack of skills, capabilities or resources in Option 1 on the basis that it would not be compatible with the revised scope of the ESRS, which will consist of the largest, most sophisticated and well-resourced companies in the EU. However, if broadening CSRD scope to include smaller entities requires some form of capabilities-based relief, we would support a proportionate approach where such reliefs apply only to smaller companies.  We agree with the concerns that Option 2 would result in the loss of highly material and decision-useful information for investors. It is also a critical component of the CSRD's financial materiality lens, as evidenced by its inclusion across all main standards that adopt a 'single materiality approach' (ISSB, TCFD, etc). We acknowledge that these disclosures can be particularly challenging, but methodologies and practices have improved in recent years and to make these disclosures voluntary would represent a significant step backwards. Supporting implementation guidance could be developed to further accelerate progress in this area."]
["Survey","Institutional Investors Group on Climate Change (IIGCC)","NGO","United Kingdom","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","We are broadly comfortable with the changes made to datapoints within the Environmental Standards that correspond to SFDR PAIs. We acknowledge and welcome the proposed deletion of wording in ESRS E1-5 that would limit disclosure to high impact sectors only. Disaggregated information on energy usage (particularly of fossil fuels) is a highly decision-useful datapoint irrespective of sector as it enables the measurement of energy efficiency improvements amongst other issues. While we agree that it should still be feasible for users of reporting to derive some of the deleted datapoints from information published elsewhere, we note that in some cases the numerator (emissions) and the denominator (energy consumption) where disclosed separately are often on an inconsistent boundary."]
["Survey","Institutional Investors Group on Climate Change (IIGCC)","NGO","United Kingdom","35.E1-9."," Do you agree with the amendments of this chapter? ","I disagree","We are concerned about the deletion of the provision requiring explanations on residual GHG emissions and neutralisation pathways. While we note stakeholder concerns over the reliability of long-term projections, it is precisely this uncertainty that made the disclosures of underlying assumptions so useful.","E1","Disclosure Requirement E1-9 - GHG removals and GHG mitigation projects financed through carbon credits",""]
["Survey","TomTom NV","Preparer (non-financial preparing a sustainability report)","Netherlands","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Understandability has been improved: in particular, ''Application Requirements'' section is better presented."]
["Survey","TomTom NV","Preparer (non-financial preparing a sustainability report)","Netherlands","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","We disagree on the changes on G1: we believe they should not be mandatory but rather kept them voluntary."]
["Survey","Forvis Mazars Group","Auditor","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Forvis Mazars Group","Auditor","Belgium","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We appreciate EFRAG's efforts to preserve interoperability with IFRS SDS as much as possible considering the overall objective of burden reduction. It is indeed key to avoid duplication of efforts and to ensure that information presented under different frameworks is comparable to the greatest extent possible.  Nevertheless, we question why different wording has been used in the proposed revised Standards where ESRS are meant to be fully aligned with IFRS SDS (e.g. the fair presentation principle, the general \"undue cost or effort\" relief, etc.). Wording that is not fully aligned without proper justification will inevitably create confusion and unnecessary analysis for companies reporting under both frameworks. Overall, we encourage EFRAG to use as much as possible the same language as the one used in IFRS SDS when the underlying principle, relief or requirement is meant to be the same.  Even more, there are important areas where interoperability could be further enhanced without undermining the EC's simplification objective. Especially, we regret that EFRAG is not proposing to fully align with IFRS S2 regarding the reporting of GHG emissions by allowing companies to decide on which approach offered by the GHG Protocol it wishes to apply. Above all, this would reduce complexity for companies used to applying the GHG Protocol. This being said, we also note that the GHG Protocol is currently under revision and that referring to all options in the GHG Protocol would probably imply that EFRAG reinforce its collaboration with the Protocol."]
["Survey","Forvis Mazars Group","Auditor","Belgium","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","While it is definitely necessary to clarify the \"gross vs. net\" issue, the guidance developed is complex, theoretical and not all terms are clearly defined (example for unclear definitions: significant ongoing activities; is having a compliance office to deal with bribery and corruption an significant ongoing activity, or is fulfilling the minimum legal requirements regarding safety an significant ongoing activity?).  Differentiating between actual and potential impacts, first year and future years of occurrence is complex to communicate (1) to experts during the actual DMA and (2) to the reader of the report as she/he has not the same insights as the company itself. We would welcome a simpler and consistent application of the gross vs. net view for all IROs. It is also crucial to take into account that many industries are already highly regulated (e.g., health and safety for chemical industry or data protection for IT industry). Taking activities to fulfill such regulations not into account when assessing materiality of an IRO  would lead to many IROs becoming material."]
["Survey","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We highly welcome this flexibility. The changes in the structure of the ESRS increase their readability: having the ARs in a box right next to the respective paragraph, deleting \"explanatory\" paragraphs, and combining paragraphs makes it easier to navigate and read. The latter also increases the flexibility of companies as the paragraphs are now more principles based as they still define the data to be reported but are less prescriptive. Positive is also the increased flexibility regarding the use of tables (many are shifted to \"may present\"), the use of appendices and the possibility shift details about the GHG calculation methodology into such appendices. Lastly, also the added possibilities to (1) exclude sensitive information and to (2) exclude certain activities from metric calculations are greatly increasing flexibility without substantially decreasing information value. Despite the positive aspects, we noticed, that new mandatory disclosures have been added – clearly against the request of the EU commission and the aim of the revision to reduce reporting burden. Additional mandatory data points should be avoided."]
["Survey","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","Especially auditors have relied heavily on the checklist approach when   auditing ESRS Sustainability Statements and required companies to disclose information that would have considered non-material in other reporting frameworks. This pushed companies towards over-disclosing, usage of a highly technical language and in general an increased reporting burden. Due to fair presentation not being mentioned, the ESRS gave companies no effective argument to push back. Consequently, we expect the explicit statement of fair presentation to be a/the major relief for preparers. It is (1) easier to achieve comparability with other frameworks (esp. ISSB), it is (2) easier to streamline the presentation of information and (3) fair presentation can serve as a lever to effectively reduce disclosure overload and increase the efficiency of the reporting. However, in our opinion two aspects need to be refined (1) \"fair presentation\" should be defined within the ESRS to avoid misunderstanding (there is plenty of scientific literature about the different interpretation of \"fair presentation\" in Europe after the term was introduced in the accounting directive). When defining \"fair presentation\" we would welcome to also explicitly state that the concept of fair presentation is used to remove information but also to evaluate possible additional, entity specific information. Secondly, ESRS 1 paragraph 21 (b) in its current form (\"enable users to understand…\") might lead to even more disclosures as this formulation lacks to give preparer and auditor any guidance on how to limit disclosures (see our response to Q11)."]
["Survey","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","ESRS E.5: Feedback already given on preceding pages; only thing to add: We would appreciate a clarification whether \"thermal-based disposal\" is something different to \"thermal recovery\"."]
["Survey","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","PGE","Preparer (non-financial preparing a sustainability report)","Poland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","PGE","Preparer (non-financial preparing a sustainability report)","Poland","35.S1-16."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Data Points (DP): (S1) 97b Adequate wages Provide the ratio of the highest-paid individual's salary to the median employee salary   Comment on the challenge: The indicator does not clearly specify the group of employees for calculating the median.  Suggestion: Consider employees employed on December 31st of the given year. Active employees – excluding suspended individuals. For this group of employees, apply the same salary components as for (S1) 97a and (S1) 98 related to the pay gap. An instruction for calculation would be helpful:  1.\tCreate a list with the sum of annual salaries of employees employed on December 31st of the reporting year (excluding suspended individuals). 2.\tSort by salaries. 3.\tFind the middle position (Median), excluding the highest-paid individual. 4.\tNumerator - total annual salary for the highest-paid individual in the organization (annual highest salary).  5.\tDenominator - median annual total salary of all employees (excluding the highest-paid individual).  Data Points (DP): (S1) 97a Gender Equality and Diversity  Provide the gender pay gap between women and men, defined as the difference in the average salary level between female and male employees, expressed as a percentage of the average salary level of male employees.  Data Points (DP): (S1) 98 Gender Equality and Diversity  Provide data on the gender pay gap between women and men by employee category or by country/segment, as well as broken down into regular base pay and supplementary or variable components.  Comment on the challenge: The indicator does not clearly specify the group of employees for calculating the gender pay gap.  Suggestion: An instruction for calculation would be helpful:","S1","Disclosure Requirement S1-16 - Incidents of discrimination and other human rights incidents",""]
["Survey","The Biodiversity Footprint Intelligence Company","Consultant (including software vendor)","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The balance seems to have gone too far in the direction of burden relief. It should be adjusted back in favour of transparency. In particular, direct data should still be preferred (while estimate should be allowed, but not preferred)."]
["Survey","FERMA","Business association (other than association of financial institution)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","FERMA would like to insist on several points.  1) The assessment of materiality should be appraised on a net rather than gross basis, in a pragmatic way. Therefore, the assessment of materiality should take into account •\tThe existing mitigation measures that are intrinsic or inherent or by design to the activity (e.g. mandatory third-party approval before a product is marketed). •\tThe mitigation measures / control activities put in place by the organisation before each reassessment of the double materiality analysis.  2) If the Gross assessment approach is confirmed, sectoral guides would enable to compare different companies in a dedicated sector. The gross assessment would be the starting point for every company in the same sector. •\tThis would enable the organization to focus on the actions still to be carried out.  This would be more consistent with an Enterprise Risk Management (ERM) approach and with the global risk mapping disclosed in the dedicated chapter in the annual report of the organisations.  3) Clarify the risk manager's key role in the double materiality analysis, as he/she has the knowledge and tools needed to identify, assess and coordinate ESG risk management. •\tPooling approaches would avoid over-soliciting internal contacts. •\tIt would ensure consistency with the company's ERM system, which has the role of supervision of all risks. •\tThis would increase efficiency for the teams in charge of the analysis rather than wasting time on pedagogy towards contributors and management.  4) Overall, the DMA should be regulated on the basis of a few methodology-process requirements to make the whole process simpler (involvement of relevant stakeholders, transparency of the process, high level of governance in the results approval, existence of internal procedure, etc.) An implementation guide based on such a practical approach on these would be recommended in our view."]
["Survey","FERMA","Business association (other than association of financial institution)","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","FERMA does not have a strong view on the SFDR precisely, but we wish to recall that, since its review should be issued by the Commission by the end of the year, it is important to keep as much consistency as possible between different EU dossiers related to sustainability."]
["Survey","Seznam","Preparer (non-financial preparing a sustainability report)","Czechia","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree"]
["Survey","Generation Investment Management and Just Climate","User (analyst, data provider, rating agency, etc.)","United Kingdom","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","The draft ESRS propose new mandatory guidance on how to consider the implemented remediation, mitigation and prevention policies and actions when assessing the materiality of an impact (so called 'gross versus net' issue). Remediation (and other related) practices undertaken by an entity will affect the residual risk experienced by the entity, and we understand preparers and users' desire for guidance. That said, the proposed approach applying prescriptive instructions on how to consider mitigation, prevention and remediation actions in each situation gives rise to a new risk to interoperability, given that such prescriptive guidance does not apply under ISSB standards. An alternative approach, that would allow for continued interoperability, would be to request preparers explain which logic (gross or net) they have applied in their assessment of related risks. This would also reduce burden on preparers, as it would allow preparers to analyse and communicate risks in the manner to which they have become accustomed and/or would be preparing to do so under ISSB."]
["Survey","Generation Investment Management and Just Climate","User (analyst, data provider, rating agency, etc.)","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","In general, we believe burden on preparers would be reduced if reliefs provided for in ESRS were aligned to those provided for by ISSB. In particular, the proposal to introduce a relief relating to acquisitions and disposals acquired in the reporting period will also cause differences in the reporting boundary compared to the financial statements which will cause complexity for entities to comply with both ESRS and the ISSB Standards and affect the connectivity in information provided in sustainability disclosures and the financial statements for those using ESRS."]
["Survey","Triodos Bank N.V.","Bank","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","As Triodos Bank, we strongly support Option 1 for the relief on anticipated financial effects. The fundamental objective of the CSRD is to elevate sustainability reporting to a level of rigour and utility comparable to financial reporting. Option 2, by making quantitative disclosure entirely voluntary, undermines this core goal. It would create a significant gap in decision-useful information for investors and stakeholders, and it would fail to incentivise undertakings to develop the necessary methodologies for quantifying climate-related financial impacts. Option 1 strikes the correct and necessary balance. It establishes quantitative disclosure as the clear expectation while acknowledging legitimate current challenges. The requirement for an undertaking to explain the omission of quantitative data would be critical. This transparency provides crucial insight in itself. It forces a distinction between an inability to report due to inherent, high uncertainty versus a conscious decision not to (yet) allocate the resources or develop the capabilities to do so. This \"comply or explain\" mechanism would challenge undertakings to be transparent about their progress and priorities. It pushes the field forward by encouraging the development of more mature reporting practices, rather than allowing a default to less informative qualitative disclosures. For sustainability reporting to be truly meaningful, it must connect impacts and risks to financial figures. Option 1 is the only choice that upholds this principle and supports the long-term integrity and purpose of the ESRS framework."]
["Survey","Triodos Bank N.V.","Bank","Netherlands","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Triodos Bank maintains that both absolute and intensity-based GHG emissions targets are essential to ensure transparency, comparability, and accountability in climate-related disclosures. While intensity targets provide insight into efficiency improvements, they may obscure the actual growth in emissions resulting from portfolio expansion. Absolute targets, by contrast, reflect the total climate impact and are necessary to assess alignment with science-based decarbonisation pathways. Triodos Bank has adopted the absolute contraction approach as defined by the Science Based Targets initiative (SBTi). This approach is applied across all relevant asset classes and is supported by the Partnership for Carbon Accounting Financials (PCAF) methodology, which enables consistent and robust measurement of financed emissions.  The Bank acknowledges the complexity involved in estimating absolute targets, particularly for financial institutions. However, such complexity is not unique to the sector and should not justify exemption. Instead, Triodos advocates for harmonised and science-based disclosures that reflect the real-world impact of financial activities and support informed decision-making by stakeholders.  Importantly, Triodos Bank emphasises that high-emission sectors are precisely those in need of transition financing. Not disclosing absolute emissions risks perpetuating the financial support of high-emitting activities without sufficient accountability, thereby delaying the transition to a low-carbon economy. Transparent disclosure of absolute targets ensures that financing decisions are aligned with climate objectives and that investors have foresight into the evolution of emissions and the credibility of transition strategies. Exempting financial institutions from this requirement would undermine the integrity of the European Sustainability Reporting Standards (ESRS) and create an unlevel playing field across sectors. Triodos Bank believes that meaningful climate disclosures must go beyond compliance and reflect a commitment to fair presentation and long-term value creation. So that the financial sector works towards a long-term vision of a more sustainable and resilient society."]
["Survey","Triodos Bank N.V.","Bank","Netherlands","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Detailed comments provided by paragraph in part 3."]
["Survey","Triodos Bank N.V.","Bank","Netherlands","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Detailed comments provided by paragraph in part 3."]
["Survey","BDEW","Other - please specify (required)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","The NMIG contains many clarifications that are important for understanding the mandatory reporting requirements. In some cases, the information it provides will still be necessary for preparing the report. While moving this information into a separate document may reduce the length of the mandatory reporting standards, it also raises questions.  From our perspective, there is a considerable likelihood that auditors will rely heavily on the NMIG when interpreting requirements. Therefore, there is a risk that these guidelines will be interpreted by auditors as a kind of checklist which could even limit the adjustability to company specific content. As a result, this voluntary guideline could, in practice, become an indirect obligation. We therefore consider it important to clarify the status of the document."]
["Survey","BDEW","Other - please specify (required)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree"]
["Survey","BDEW","Other - please specify (required)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","Investors can and in practice already do address their individual requirements to their investees bilaterally. There is no need for covering the SFDR requirements in a general regulatory approach."]
["Survey","BDEW","Other - please specify (required)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","BDEW","Other - please specify (required)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Transparency International France","NGO","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","While it is positive that voluntary disclosures have been retained, the legal status of the NMIG remains unclear. This uncertainty risks limiting its effectiveness within the ESRS, as stakeholders may question the authority of the guidance. Placing voluntary disclosures in a separate document, particularly one whose legal standing is not yet defined, creates a risk that key examples will be overlooked. For example, the guidance in NMIG 1 relating to paragraph 7 (Policies – anti-corruption and bribery) which, provides important information that enables stakeholders to hold companies accountable for their approach to anti-bribery and corruption."]
["Survey","WaterAid","NGO","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","WaterAid support the introduction of the option to have an 'executive summary', as well as the option to use appendices for the most granular information. We also strongly commend the effort of EFRAG to reduce duplications, in particular in reference to PAT, which we think will significantly improve the conciseness of the reports"]
["Survey","WaterAid","NGO","United Kingdom","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","BDO","Auditor","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","BDO","Auditor","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","•\tWe support the approach to reduce the number of mandatory Application Requirements in the main body of the standard and to move illustrative content to the NMIG. We note and acknowledge that while some Application Requirements are not designated as 'shall' requirements, including certain 'may' ARs can provide helpful application guidance for users.  •\tGiven the accelerated timeline of the revised ESRS development and on the assumption that the NMIG will not form part of the Delegated Act, we strongly recommend that EFRAG revisits the NMIG with full and appropriate due process to ensure it does not introduce guidance that exceeds the scope of mandatory requirements or inadvertently creates additional disclosure obligations. The NMIG should be positioned clearly as educational and supportive material, and its content should be made more concise and robust.  •\tWe also encourage EFRAG to establish a process for updating and improving the NMIG, including full and appropriate due process to ensure that its content does not contradict the revised ESRS content and its objectives."]
["Survey","BDO","Auditor","Belgium","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","Please refer to our comments on questions 15 and 16."]
["Survey","BDO","Auditor","Belgium","22.S1","Comments on deleted datapoints in ESRS S1","I agree","Please refer to our comments on questions 15 and 16."]
["Survey","Transparency International UK ","NGO","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","We welcome the fact that the proposed amendments have retained the Double Materiality Assessment, and we believe that the amendments to the Double Materiality Assessment process have struck an acceptable balance between simplification and robustness."]
["Survey","UBE CORPORATION EUROPE","Preparer (non-financial preparing a sustainability report)","Spain","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","I think the guidelines are excessively complex and unnecessary.  Please consider that these guideline can create confussion since the undertaking have their own rules to manage the actions according the nature and the assessment of negative impacts."]
["Survey","UBE CORPORATION EUROPE","Preparer (non-financial preparing a sustainability report)","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","UBE CORPORATION EUROPE","Preparer (non-financial preparing a sustainability report)","Spain","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","UBE CORPORATION EUROPE","Preparer (non-financial preparing a sustainability report)","Spain","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","UBE CORPORATION EUROPE","Preparer (non-financial preparing a sustainability report)","Spain","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CFDT - Confédération française démocratique du travail","Trade union","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The Exposure Draft removes duplications between the cross-cutting and topical standards. The preservation of the 4-part architecture in the social standards is important to respect the distinctiveness of different affected stakeholder groups.     However, we have two critical concerns ;  First, the original DR in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. We welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened.  Second, we strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics should not imply that entity-specific metrics for S topics should not be disclosed."]
["Survey","CFDT - Confédération française démocratique du travail","Trade union","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material.  Reporting on financial effects is crucial to achieving the objective of putting sustainability reporting on the same level as financial reporting and integrating both. The European Union has recognised the value of a double materiality approach to corporate reporting which requires disclosure of both material environmental and social impacts, risks and opportunities as well financially material data, It is important to keep the requirement on businesses to analyse and understand the financial effects of their business model. This will ensure investors have access to credible data as well as providing the underpinning for future business planning."]
["Survey","CFDT - Confédération française démocratique du travail","Trade union","France","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The \"top 10\" threshold for reporting country-level data on employment, collective bargaining and social dialogue is a major improvement over the current 10% employment threshold. An analysis of the first sustainability statements from Wave 1 companies shows that the current 10% threshold results in country-level disclosures on as little as 21% of total employees. More country-level information is needed to understand the distribution of impacts across countries, as well as whether employment thresholds for specific labour rights have been exceeded.  The new threshold does not require additional effort/cost by companies, since they must gather country-level data anyways to calculate the global figures. Furthermore, it does not result in extra datapoints, since the information currently is (and can be under the revised ESRS) reported as one table."]
["Survey","CFDT - Confédération française démocratique du travail","Trade union","France","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","An explicit reference needs to be added to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S3, to clarify that metrics need to be reported in the case of entity-specific impacts."]
["Survey","Bundesverband Deutscher Leasing-Unternehmen e. V..","Association of financial institutions","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","this is useful and beneficial"]
["Survey","Bundesverband Deutscher Leasing-Unternehmen e. V..","Association of financial institutions","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Bundesverband Deutscher Leasing-Unternehmen e. V..","Association of financial institutions","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","A precise definition from EFRAG of what is meant by 'serious human rights violations' would be helpful."]
["Survey","Bundesverband Deutscher Leasing-Unternehmen e. V..","Association of financial institutions","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Bundesverband Deutscher Leasing-Unternehmen e. V..","Association of financial institutions","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","InfraMobility","Preparer (non-financial preparing a sustainability report)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree"]
["Survey","InfraMobility","Preparer (non-financial preparing a sustainability report)","Belgium","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","UNEP-WCMC","NGO","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","UNEP-WCMC","NGO","United Kingdom","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","See detailed comments in Part 3."]
["Survey","UNEP-WCMC","NGO","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Regarding ESRS E4 Disclosure of transition plan, it is good that disclosing a transition plan is made mandatory. However, this does not likely apply to many companies, because 'Disclosing information on a transition plan (TP) is conditional to have one that is publicly released.' We recommend removing this condition. The data points should be applied to all companies that have in their materiality assessment identified high risks and dependencies on nature."]
["Survey","Koan Group","Consultant (including software vendor)","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","The introduction of several targeted reliefs demonstrates a practical understanding of the challenges faced by preparers during the first application of the ESRS, particularly regarding value chain data collection.  The changes introduced, such as the new relief for acquisitions/disposals and the clarification on disclosing financial effects (limiting information to already announced investments and plans), are necessary to align reporting with common corporate practices.  The most critical area of relief is the systematic removal of the preference for direct data in value chain metrics. This change is crucial, as the initial reliance on direct data was a major point of burden. Allowing undertakings to use reliable estimates substantially reduces reporting effort and acknowledges the practical limitations of primary data collection.   Similarly, introducing a relief for lack of data quality (allowing partial scope reporting with an action plan to improve future coverage) makes sense, as it avoids penalising companies for first-time data gaps while committing them to continuous improvement.  However, the new \"undue cost or effort\" relief may complicate matters regarding audit consistency. There is currently a lack of clarity on who validates whether the data collection was causing undue cost and how auditors will ensure the same criteria are applied across different companies to prevent arbitrary reporting boundaries.  The relief concerning the systematic preference for direct data introduces a significant risk that data quality will be diminished. There is a concern that companies may not actively pressure suppliers to collect relevant data, which is essential for accountability. This aspect requires close monitoring to ensure the transparency of actual impacts is not compromised."]
["Survey","Koan Group","Consultant (including software vendor)","Netherlands","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","The rationale for exemption, while acknowledging implementation difficulties, fundamentally conflicts with the goal of driving real-world decarbonisation and maintaining market transparency.  Particularly, intensity targets can mask rising absolute emissions that result from business growth. An FI could meet an intensity target while simultaneously increasing the total volume of emissions it finances. Absolute targets counter this risk by capturing the true, total impact on the climate.  Since banks and insurers are driving decarbonisation, it is crucial that they disclose their ambition to reduce total, real-world emissions. By publishing this information, FIs create both an internal commitment and an external signal of their role in the low-carbon transition."]
["Survey","Koan Group","Consultant (including software vendor)","Netherlands","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The new threshold, requiring disaggregation for the top 10 largest countries by employee headcount, is a vast improvement because  ensures that the social disclosures reflect the countries where the undertaking has its most significant workforce presence.    This information is typically easily accessible by country, as companies already track employee headcount and location for payroll and human resources management. Therefore, the incremental burden of disaggregating this specific data for the top 10 countries is estimated to be limited for most companies.  Lastly, by standardising the disclosure to the top 10 countries, the amendments establish a consistent benchmark across similar multinational undertakings, significantly improving the comparability of social metrics."]
["Survey","Koan Group","Consultant (including software vendor)","Netherlands","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","E3G - Third Generation Environmentalism","NGO","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","E3G - Third Generation Environmentalism","NGO","United Kingdom","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","E3G welcomes EFRAG's proposed changes to simplify the ESRS by reducing the number of datapoints, introducing specific reliefs, and shortening the length of the ESRS format.    We believe the removal of all 'may disclose' elements is helpful to streamline the standards. Nonetheless, not all such elements need to be transposed in the Non-mandatory Illustrative Guidance (NMIG). In doing so, corporate entities would need to review additional guiding documents on top of existing implementation guidelines. This would be difficult to incentivise systematically and would go against the principle of simplifying the reporting process.    If needed, E3G believes that it would be more effective to have the most relevant 'may disclose' elements within the ESRS framework, in the format of examples and references to existing disclosure requirements."]
["Survey","E3G - Third Generation Environmentalism","NGO","United Kingdom","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome that the EFRAG's proposal does not propose any radical changes to the transition plan criteria under E1-1. In particular, we acknowledge that the new format of E1-1 paragraph 14 covers fully the transition plan criteria under CSDDD Art.22. This level of technical alignment across EU regulation is exactly what the Omnibus I should achieve with its process."]
["Survey","Disability:IN","NGO","United States","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Disability:IN","NGO","United States","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Disability:IN","NGO","United States","35.S1-16."," Do you agree with the amendments of this chapter? ","I agree",null,"S1","Disclosure Requirement S1-16 - Incidents of discrimination and other human rights incidents",""]
["Survey","UNICEF","NGO","United States","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","UNICEF","NGO","United States","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","European Works Council","Trade union","Austria","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","European Works Council","Trade union","Austria","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","The new, simplified framework makes it easier for companies to report on these SFDR-related matters in a way that corresponds to how their policies are set. For users, this consolidation makes it easier to locate the relevant information. However, the SFDR datapoints are very helpful and should only selectively be amended."]
["Survey","European Works Council","Trade union","Austria","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We are concerned that the loss of many specific datapoints related to workers in the value chain will mean that disclosures about material impacts, risks and opportunities become more generic and have less information about the specific stakeholder groups because specifications about the level of granularity have been deleted. Many of the points that are being deleted from ESRS S2 had originally been included because they reflected effective practice in relation to improving supply chain labour rights, for example, AR 6 awareness of the impacts on value chain workers from an undertaking's strategy or business model, AR 20 illustrating how the perspectives of value chain workers have informed specific decisions or activities of the undertaking and AR 25 which looks at retaliation and whether workers can use grievance mechanisms confidentially."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","22.S2","Comments on deleted datapoints in ESRS S2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","."]
["Survey","Punto 3 S.r.l. S.B.","Consultant (including software vendor)","Italy","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","."]
["Survey","Panasonic Holdings Corporation","Preparer (non-financial preparing a sustainability report)","Japan","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","We welcome EFRAG's efforts to address the practical concerns of preparers. The introduction of burden relief measures is an important step that will support the effective and realistic implementation of the CSRD. In particular, these reliefs acknowledge the current challenges around data quality and availability—especially in relation to value chain information—which will require time to develop and mature. Just as it took many years for financial reporting to reach its current level of robustness and comparability, sustainability reporting should similarly be allowed to evolve along a learning curve. The introduction of these reliefs not only supports preparers during this transition period but also provides stakeholders with greater transparency regarding existing data limitations and the areas where further maturity is needed."]
["Survey","Panasonic Holdings Corporation","Preparer (non-financial preparing a sustainability report)","Japan","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","We believe the principle of fair presentation is important in sustainability reporting. However, there are concerns about its practical application, especially regarding impact information. Such information frequently depends on estimates or assumptions, which can vary significantly depending on the methodologies and data sources employed. This inherent variability can affect both comparability and neutrality—core elements of the fair presentation principle. Furthermore, sustainability statements frequently include future-oriented targets, which by their nature involve uncertainties and risks, making faithful representation inherently challenging. While we acknowledge and support the importance of fair presentation, its practical implementation faces several obstacles. Overcoming these will require robust frameworks, clearer methodologies for diverse data points, and stronger assurance practices. Without these, we share the concerns expressed by EFRAG SRB members that this could lead to increased auditing costs."]
["Survey","Panasonic Holdings Corporation","Preparer (non-financial preparing a sustainability report)","Japan","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Panasonic Holdings Corporation","Preparer (non-financial preparing a sustainability report)","Japan","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Japan Foreign Trade Council, Inc.","Business association (other than association of financial institution)","Japan","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Japan Foreign Trade Council, Inc.","Business association (other than association of financial institution)","Japan","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","We are opposed to amendments that would harm the comparability of global sustainability reporting—that is, amendments that would cause additional differences from the ISSB standards (or, for Japan, the Sustainability Standards Board of Japan [SSBJ] standards) . For example, regarding reporting on greenhouse gas emissions, the Exposure Drafts stipulate that, even if the financial control approach is selected, an additional disclosure following the operational control approach be required in certain circumstances. （E1 AR19 for para 32） However, there are no such requirements in the ISSB standards. Because there are concerns that such differences among standards would not only create a duplicate burden on the non-EU companies subject to the extraterritorial application of the ESRS but also harm the global comparability of sustainability reporting, we request further elimination of differences among standards.  Additionally, whereas the Amended ESRS 2 Exposure Draft proposes two disclosure methods to reduce the burden of disclosing quantitative information about anticipated financial effects, we request that the option mandating qualitative information only be adopted for the purpose of reducing the burden of preparers. The problem, however, is that this option would result in differences from the ISSB standards that require disclosure of quantitative information.  Accordingly, to maintain consistency with the ISSB standards, we would like the European Financial Reporting Advisory Group (EFRAG) to urge the IFRS Foundation to implement amendments similar to the ESRS. If the amendment of the ISSB standards is difficult, then we request retaining the current ESRS provision (exemption from quantitative information disclosure only in cases where certain conditions are met) that is similar to the ISSB standards, as we believe that priority should be given to reducing the differences among standards."]
["Survey","UN Global Compact Country Network Spain","Standard setting initiative","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We welcome the introduction of the \"undue cost or effort\" relief in ESRS 1, as it allows companies to disclose partial metrics when they lack reliable data. The flexibility to report partial data while continuing to work towards better data quality is an important step in reducing the reporting burden without compromising the overall transparency of the sustainability reports.  However, we believe that while this relief is necessary, it is important to ensure that companies do not use this relief indefinitely. The disclosure of actions to improve the scope of the metrics in future periods is crucial, as it provides transparency and incentivizes companies to make efforts to improve data quality over time. Without a time limit for the use of this relief, there is a risk that some companies may continue to rely on it without taking sufficient steps to enhance their data systems.  We agree with the general direction of the amendment but recommend that a time limit for the use of this relief be introduced. This would ensure that companies remain accountable for their data quality improvement and do not use the relief as an excuse for ongoing lack of data reliability. This time limit should be extended if there is a significant change in the company, such as a restructuring, merger, or takeover."]
["Survey","UN Global Compact Country Network Spain","Standard setting initiative","Spain","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","The removal of less relevant datapoints, particularly in the narrative PAT disclosures, aligns with the objective of simplifying the reporting process while still ensuring that companies provide material and relevant information to investors and stakeholders.  However, we have concerns about the potential loss of critical information that could be valuable for investors, especially regarding the financial effects of material climate risks, stranded assets, and transition opportunities. These types of data are essential for investors to assess a company's long-term sustainability performance, and their omission could limit transparency.  While we agree with the general direction of simplifying the reporting framework, it is important to ensure that the reduced datapoints still allow for comprehensive disclosures that align with the EU Green Deal objectives. The Ten Principles of the UN Global Compact, including those related to human rights, decent work, and environmental responsibility, must remain central to any sustainability reporting framework. Maintaining the relevance and comparability of the disclosed information is crucial for investors and lenders to make informed decisions about sustainability risks and opportunities."]
["Survey","UN Global Compact Country Network Spain","Standard setting initiative","Spain","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","The removal of less relevant datapoints, particularly in the narrative PAT disclosures, aligns with the objective of simplifying the reporting process while still ensuring that companies provide material and relevant information to investors and stakeholders.  However, we have concerns about the potential loss of critical information that could be valuable for investors, especially regarding the financial effects of material climate risks, stranded assets, and transition opportunities. These types of data are essential for investors to assess a company's long-term sustainability performance, and their omission could limit transparency.  While we agree with the general direction of simplifying the reporting framework, it is important to ensure that the reduced datapoints still allow for comprehensive disclosures that align with the EU Green Deal objectives. The Ten Principles of the UN Global Compact, including those related to human rights, decent work, and environmental responsibility, must remain central to any sustainability reporting framework. Maintaining the relevance and comparability of the disclosed information is crucial for investors and lenders to make informed decisions about sustainability risks and opportunities."]
["Survey","UN Global Compact Country Network Spain","Standard setting initiative","Spain","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The Application Requirements for disclosure requirement S1-9 set out the methodology for reporting on employees' wages in relation to an adequate wage. The methodology references one norm for 'adequate wages' with regard to employees within the EU (namely, the adequate wage as defined in EU Directive (EU) 2022/2041) and a different norm for employees outside the EU (namely the legal minimum wage). This creates a number of problems:  •\tThe reference to legal minimum wages is not reflective of the title or purpose of the disclosure requirement. •\tIt is discriminatory since the legal minimum wage is typically lower than an adequate or living wage estimate,  and it therefore implies that the EU expects lower wage standards for employees outside the EU. •\tIt creates confusion for companies, for which it is simpler and more appropriate to apply one reference norm across all their employees. •\tIt makes the information reported by companies incomparable, since some have used the minimum wage and others have selected to apply the living wage estimate they use elsewhere."]
["Survey","UN Global Compact Country Network Spain","Standard setting initiative","Spain","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We partially agree with the simplifications introduced in the Amended ESRS. The reduction of datapoints and clarification of provisions are positive steps towards streamlining sustainability reporting. However, it is important to ensure that these simplifications do not compromise the integrity and transparency of information on key areas such as human rights, labor standards, and environmental sustainability.  While the simplification of reporting requirements is necessary, companies must continue to provide detailed disclosures on their impact in these areas to ensure they are upholding their commitments to the UN Global Compact's Principles. This will also contribute to the achievement of relevant SDGs, ensuring that companies remain aligned with global sustainability goals.  In conclusion, while we support the direction of the simplifications, it is crucial that the balance between reducing reporting burdens and maintaining relevant and comprehensive disclosures is carefully monitored. This will ensure that companies continue to meet their sustainability obligations effectively, in line with both the UN Global Compact and the SDGs."]
["Survey","UN Global Compact Country Network Spain","Standard setting initiative","Spain","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","We partially agree with the simplifications introduced in the Amended ESRS. The reduction of datapoints and clarification of provisions are positive steps towards streamlining sustainability reporting. However, it is important to ensure that these simplifications do not compromise the integrity and transparency of information on key areas such as human rights, labor standards, and environmental sustainability.  While the simplification of reporting requirements is necessary, companies must continue to provide detailed disclosures on their impact in these areas to ensure they are upholding their commitments to the UN Global Compact's Principles. This will also contribute to the achievement of relevant SDGs, ensuring that companies remain aligned with global sustainability goals.  In conclusion, while we support the direction of the simplifications, it is crucial that the balance between reducing reporting burdens and maintaining relevant and comprehensive disclosures is carefully monitored. This will ensure that companies continue to meet their sustainability obligations effectively, in line with both the UN Global Compact and the SDGs."]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We fully support the changes that make a clear distinction between mandatory and voluntary datapoints. This was one of the main sources of confusion when preparing sustainability statements and also created challenges with auditors.  To make the ESRS even simpler, EFRAG could move definitions to the Annex II glossary, place illustrative examples in the NMIG, include presentation guidance directly in the datapoints, and remove optional ARs.  In addition, the term \"significant\" is unclear. ESRS should explain that companies should assess significance in their own context, so that disclosures remain relevant and material."]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","We welcome the simplifications made in this requirement, but we still question the need for quantitative data. Companies highlight that preparing cash-flow forecasts is very difficult and can raise issues of confidentiality, strategy, and liability. We believe that investors are best placed to build their own forecasts based on information already disclosed by companies, such as business model, risks, historical data, and targets.  We suggest that the ESRS should include the reliefs from IFRS S1 (§38 and §39), which allow companies not to disclose quantitative data when:  the effects cannot be separately identified,  the measurement uncertainty is too high, or  the company does not have the skills or resources to prepare the data.  Consistent with our response to Question 19, we support Option 2 and recommend that quantitative disclosures remain voluntary.",null,null,""]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","We support the deletion of that mandatory datapoint as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","n/a"]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","KGHM POLSKA MIEDŹ S.A.","Preparer (non-financial preparing a sustainability report)","Poland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"n/a"]
["Survey","Coop Italia","Preparer (non-financial preparing a sustainability report)","Italy","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Requesting at least qualitative data may be reasonable"]
["Survey","WeeFin","User (analyst, data provider, rating agency, etc.)","France","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","WeeFin supports the implementation of an executive summary at the beginning of the report. It would be interesting to provide examples of best practices to enable companies to target the important information that is specific to them, and needed to be included in an executive summary (e.g., GHG emissions, GHG emission reduction targets, etc.).  WeeFin supports also a better connectivity with corporate reporting only if it enables the initial requirements of the CSRD to be met effectively, transparently, and simply (i.e., if the datapoint is replaced with a reference to a document where the information is difficult to access or find, then the requirements are not met)."]
["Survey","WeeFin","User (analyst, data provider, rating agency, etc.)","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Even if the amendment generally brought improvement to the ESRS 2, we disagree with some reduction proposals.  Firstly, regarding amendment of topical specification, the new key stakeholders category introduced in ESRS 1 and referred to in AR of ESRS 2 - SBM2, does not fully cover the actors that were included in the previous SBM topical specification. Especially, information on integration of interest, views and right of value chains workers in undertakings' strategy and business model are now excluded.  Secondly, we disagree with the removal of the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline. From our point of view, this information is important as it allows recognition of transition effort, and incents undertakings to engage on new topics."]
["Survey","WeeFin","User (analyst, data provider, rating agency, etc.)","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","WeeFin mostly disagrees with the substantial reduction in the number of mandatory and voluntary data points for multiple reasons: 1- It is important to remember that with regulations such as CSRD or SFDR, Europe is imposing its vision on the world economy and regaining leverage over its sovereignty.While extra-financial reporting can pose a challenge to the competitiveness of European companies, the reporting obligation for non-European companies should be maintained. Many financial sector players already comply with European standards like SFDR, drawn by the attractive European market, even with additional compliance rules. It is essential to recognize that regulations such as CSRD and SFDR allow Europe to assert its vision in the global economy and enhance its sovereignty. 2- By reporting on all material metrics, companies can secure funding and implement measures to build resilience against ESG risks. This is especially crucial given the sharp increase in physical risks, with significant shifts expected from 2030 onwards. Proactive engagement now is essential for resilience, as insurers will also be scrutinizing and holding companies accountable. 3/ First reports from 2025 demonstrate the feasibility and utility of CSRD for businesses, as well as its necessity for the economy. Companies that publish more maintain greater control over their communications and strategic plans. In the current era of AI and geospatial data, data will inevitably be generated. It's crucial to remember that 90% of ESG data utilized in finance is modeled. Therefore, a lack of publication can lead to non-European data providers modeling this information, potentially impacting competitiveness and data sovereignty. In conclusion, the removal of voluntary reporting does not appear to be consistent, and switching certain indicators from \"mandatory\" to \"voluntary\" would be more acceptable."]
["Survey","WeeFin","User (analyst, data provider, rating agency, etc.)","France","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The requirement to disclose assessment methodology of \"impact on climate change, in particular, undertaking GHG emissions\" has been deleted but not replaced in the amended ESRS E1. We think that this disclosure could be useful to maintain from a data quality perspective as CSRD could at a point apply to undertakings that are not experienced in reporting their GHG emissions."]
["Survey","WeeFin","User (analyst, data provider, rating agency, etc.)","France","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Atenor","Preparer (non-financial preparing a sustainability report)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","FAR AB","Business association (other than association of financial institution)","Sweden","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","FAR agrees the proposed amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives.  Full interoperability would mean directly referencing to the GHGP, however on the detriment for comparability since the GHGP opens for two alternatives.   The financial control boundary is clear and aligned with the reporting boundary in ESRS 1. The financial control boundary strikes the right balance between simplification, comparability and usefulness when taking into consideration the guidance in AR 19."]
["Survey","FAR AB","Business association (other than association of financial institution)","Sweden","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","Some actors obliged to report under the SFDR may find it burdensome to interpret or calculate, from other datapoints, the removed PAI-indicators.  FAR would like to stress the need for SFDR and ESRS to be synchronized. The development of SFDR should follow ESRS. Thus, if certain PAI:s have been removed from ESRS it should be because they are also to be removed from SFDR."]
["Survey","Unione Energie per la Mobilità Unem","Business association (other than association of financial institution)","Italy","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We strongly support the provisions outlined in ESRS 1, paragraph 92, which recognize the practical limitations of data availability in joint operations where the undertaking lacks operational control. Allowing the exclusion of such operations from the scope of environmental metric calculations is a pragmatic and necessary relief that enhances the feasibility and integrity of sustainability reporting and avoids duplicative reporting. In addition, we endorse the flexibility provided under ESRS 1, paragraph 91, which permits the use of metrics based on a partial scope of calculation. This approach acknowledges the evolving nature of data systems and reporting capabilities. Crucially, it encourages transparency by requiring undertakings to disclose the limitations of their current data coverage and to outline concrete actions aimed at improving completeness in future reporting periods."]
["Survey","Unione Energie per la Mobilità Unem","Business association (other than association of financial institution)","Italy","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","Unione Energie per la Mobilità Unem","Business association (other than association of financial institution)","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Zentralverband des Deutschen Handwerks - German Confederation of Skilled Crafts and Small Businesses","Business association (other than association of financial institution)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Partially: Strengthening the use of estimates instead of direct data regarding the supply chain is to be welcomed.  Giving them the same priority is a first step. Especially, for micro and small enterprises the overall cost-benefit-relation of direct data compared to estimates remains questionable. Thus, estimates should be prioritized. Also scope 3 GHG emissions should rely more on estimates or similar data instead of approaching every enterprise in the value chain individually."]
["Survey","Global Child Forum","NGO","Sweden","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The proposed methodology for reporting on adequate wages is flawed because it undermines the objective, introduces discriminatory and inconsistent standards, places an unrealistic burden on companies, and compromises the comparability and usefulness of disclosures.  The methodology for reporting on 'adequate wages' should measure actual wages against an adequate/living wage for all employees, not only those within the EU. In particular, for employees outside the EU, the methodology should allow employees' actual wages to be measured:  a. against the local legal minimum wage only when this is set in line with the ILO principles on estimating living wages; or  b. against living wage estimates that are set in line with ILO principles on estimating living wages.  Companies should be able to rely on local legal minimum wages or living wage estimates when the authorities or organisations that set them provide public evidence of their alignment with the ILO principles for estimating living wages. This will avoid companies' having to make this assessment themselves."]
["Survey","Global Child Forum","NGO","Sweden","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We welcome that the definition of child labour in the ESRS Glossary remains unchanged. It is consistent with the international child rights legal framework, including the UN Convention on the Rights of the Child and ILO Conventions."]
["Survey","Fair Trade Advocacy Office","NGO","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","Yes—ESRS already rest on materiality and, as such, are subject to a fair-presentation regime. Making that principle explicit is useful: it clarifies that preparers must exercise informed judgment and discretion, while applying appropriate safeguards against bias, omission, or cherry-picking. Clear articulation of fair presentation sets expectations for how companies balance relevance and reliability, how they justify boundary and scoping choices, and how they document the reasoning behind them. In short, the explicit statement improves clarity and supports consistent, decision-useful reporting."]
["Survey","Fair Trade Advocacy Office","NGO","Belgium","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fair Trade Advocacy Office","NGO","Belgium","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","UIL","Trade union","Italy","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The \"may\" (voluntary) data points should not be eliminated. In many cases they are \"shall\" in GRI standards, so it is important to keep them to align with GRI standards. Also, many of them were originally proposed as mandatory by EFRAG to the EC. The first wave of reports show that many companies have reported some \"may\" data points. Retaining them would help ensure standardization/comparability between company reports. Almost all of the datapoints for non-employee workers are voluntary, thus most datapoints for this vulnerable group of workers has been lost. Also, important datapoints on full time versus part time workers has been eliminated."]
["Survey","UIL","Trade union","Italy","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Adding a datapoint on training of the procurement team is needed to support the implementation of human rights in the supply chain. The addition of a datapoint on confirmed incidents of bribery is needed to improve transparency on the effectiveness of bribery/corruption policies and measures."]
["Survey","UIL","Trade union","Italy","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","An analysis of the first year ESRS reports shows that most companies are simply reporting that they pay minimum wages, whereas the intention (as outlined in the ESRS Basis for Conclusions) is that companies should be enabled to disclose commitments to paying a wage \"sufficient to support themselves and their families in dignity\" as well as the extent to which they do this. This shows that the methodology for non-EU countries needs to be changed. Furthermore, the new ILO agreement on a methodology for living wages needs to be taken into account. While the proposed new methodology takes a step forward in both regards, two key changes are needed:  •\tThe methodology for reporting on 'adequate wages' should measure actual wages against an adequate/living wage for all employees, not only those within the EU. In particular, for employees outside the EU, the methodology should allow employees' actual wages to be measured: o\tA) against the local legal minimum wage only when this is set in line with the ILO principles on estimating living wages; or o\tB) against living wage estimates that are set in line with ILO principles on estimating living wages. •\tCompanies should be able to rely on local legal minimum wages or living wage estimates when the authorities or organisations that set them provide public evidence of their alignment with the ILO principles for estimating living wages.  Furthermore, the transitional provision for the EU needs to be reinstated, as not all Member States have transposed the Adequate Minimum Wage Directive."]
["Survey","UIL","Trade union","Italy","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","An explicit reference needs to be added to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, to clarify that metrics need to be reported in the case of entity-specific impacts."]
["Survey","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Overall, the removal of redundancies with topical disclosures has made the requirements clearer and more manageable, while still ensuring the relevance and comparability of the information disclosed. We appreciate the move of general disclosures in topic-specific standards to ESRS 2.; and the streamlining of ARs and location under DRs.  However, regarding GOV-4, para. 15, we find that information on the significant risks and corresponding measures is lacking. This is particularly noteworthy because AR 6 also refers to individual risk factors. In SBM-1 para. 18, we can imagine that the currently missing information (as examples) on what is to be described/reported will lead to very different results and thus poorer comparability."]
["Survey","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Generally, we support the aim of the reduction of data points and helps reducing the reporting burden while preserving the core objective of structured and comparable sustainability reporting. However, due to the way in which the reduction was achieved, we see a significantly lower effect on the actual reporting effort. It is important to emphasize that a 57% reduction in mandatory data points does not automatically result in a corresponding decrease in the length of reports or the overall reporting burden. There are improvements, but overall, the standards remain very complex and extensive.   We appreciate the emphasis on prioritizing quantitative data points over detailed narrative disclosures, as well as the clear differentiation between mandatory and voluntary requirements. Nevertheless, we note that certain sections of the ESRS text remain ambiguous or predominantly descriptive."]
["Survey","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria","35.ESRS1_3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","We think that a clear clarification, differentiation, and definition for actual and potential impacts as well as a clear definition of negative human rights impact (including examples) is needed. We miss information in ESRS regarding initial consolidation and deconsolidation and the respective handling of comparative information, targets etc. in the first and following years. Further, we suggest ensuring sufficient information on IRO by clarifying undue cost and effort. Finally, we suggest clarifying practical considerations, in particular on the top-down approach (assumed material or not, assessment at topical level incorporates IROs).","ESRS1","3. Double materiality as the basis for sustainability reporting",""]
["Survey","Stellenbosch University Business School","Academia","South Africa","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The use of the terminology \"top down\" versus \"bottom up\" in materiality determination may be confusing, as some may associate this with top down data generation & analysis (incl modelling) versus bottom up data collection. At stake here is not so much the \"level of reporting\". The annual report is an overall organisation level report, while there is a separate role of lower level for example site level disclosures and communications (e.g. with local communities). So overall organisation level (entity) performance is the focus. And rather than top down or bottom up, what you are describing is either a deductive vs inductive approach or a set menu vs open menu approach. If the ESRS lists core topics to report on as a mandatory requirement across all sectors, that would have been a set menu approach. But the voluntary requirement leaves more scope for an a la carte (open menu, considering industry context) approach.  You can be forgiven for being more mandatory at topic (core subject as per ISO 26000) level, but allowing more flexibility at sub-topic level. The elimination of sub-sub-topic level is understandable in the effort to avoid excessive detail across the board."]
["Survey","Stellenbosch University Business School","Academia","South Africa","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The IFRS relief is flexible enough. At stake here is not only the omission of quantitative (financial) information, but also the nature of the qualitative information provided. The qualitative narrative one would expect to refer to likely financial impact areas (financial value driver / performance areas) without being able to provide exact financial figures. This is what investors would expect in a company engagement."]
["Survey","Stellenbosch University Business School","Academia","South Africa","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Mindful that high climate impact sectors need transitional finance, the responsible investor also needs to know in how far a financial institution while making progress in intensity may be progressing (trend over time) to an unacceptable absolute level of exposure to high climate impact entities / industries."]
["Survey","Stellenbosch University Business School","Academia","South Africa","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","KPMG IFRG Limited","Auditor","United Kingdom","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We acknowledge the intention to provide relief for lack of data quality on metrics under chapter 7.4 of ESRS. However, excessive relief could diminish the usefulness and comparability of reported information and we therefore question the need for an additional open-ended data quality relief in addition to the undue cost or effort provision.   Such relief could also create practical challenges for assurance providers in assessing whether the omission of information is justified and in providing assurance on partially estimated metrics.   Accordingly, we recommend that any additional relief related to data quality be clearly justified, restricted to a defined timeframe, and accompanied by suitable application guidance to avoid arbitrary or indefinite omissions."]
["Survey","KPMG IFRG Limited","Auditor","United Kingdom","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","trade union vida","Trade union","Austria","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The \"may\" (voluntary) data points should not be eliminated. In many cases they are \"shall\" in GRI standards, so it is important to keep them to align with GRI standards. Also, many of them were originally proposed as mandatory by EFRAG to the EC. The first wave of reports show that many companies have reported some \"may\" data points. Retaining them would help ensure standardization/comparability between company reports. Almost all of the datapoints for non-employee workers are voluntary, thus most datapoints for this vulnerable group of workers has been lost. Also, important datapoints on full time versus part time workers has been eliminated."]
["Survey","trade union vida","Trade union","Austria","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Adding a datapoint on training of the procurement team is needed to support the implementation of human rights in the supply chain. The addition of a datapoint on confirmed incidents of bribery is needed to improve transparency on the effectiveness of bribery/corruption policies and measures."]
["Survey","trade union vida","Trade union","Austria","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","ESRS S1: The proposed \"top 10\" threshold for the reporting of country-level information for employee headcount, collective bargaining and social dialogue is a significant improvement over the current 10% employment threshold. Country-level information needs to be reported in more detail, and on other metrics as well, in order to have more transparency on the distribution of impacts across countries. In the metrics, voluntary datapoints need to be reinstated as well as the datapoints on gender breakdowns, workforce age distribution, etc. detailed above need to be reinstated. The proposed new methodology for adequate wages outside of the EU also needs attention, and the transition language for EU member states needs to be reinstated, since the Adequate Minimum Wage Directive has not been implemented in some Member States. We would also like to reiterate our longstanding demand for including franchise workers in the S1 definition of own workers, as well as the need for sector-specific standards to supplement the Set 1 sector-agnostic standards.    ESRS S1, S2, S3, S4: An explicit reference needs to be added to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, to clarify that metrics need to be reported in the case of entity-specific impacts."]
["Survey","trade union vida","Trade union","Austria","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The definition of own workforce should be expanded to include franchise workers. The term \"non-employees\" should be supplemented with the phrase \"non-employee workers\" or \"non-employee workers in own workforce\"."]
["Survey","Austrian Chamber of Tax Advisers and Public Accountants (KSW, Kammer der Steuerberater:innen und Wirtschaftprüfer:innen","Auditor","Austria","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Austrian Chamber of Tax Advisers and Public Accountants (KSW, Kammer der Steuerberater:innen und Wirtschaftprüfer:innen","Auditor","Austria","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Austrian Chamber of Tax Advisers and Public Accountants (KSW, Kammer der Steuerberater:innen und Wirtschaftprüfer:innen","Auditor","Austria","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","European Renewable Gas Registry","Other - please specify (required)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Kirchhoff Consult","Consultant (including software vendor)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Kirchhoff Consult","Consultant (including software vendor)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Kirchhoff Consult","Consultant (including software vendor)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Kirchhoff Consult","Consultant (including software vendor)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Kirchhoff Consult","Consultant (including software vendor)","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Verband kommunaler Unternehmen e.V.","Business association (other than association of financial institution)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","All material sustainability risks can and must be reported in the risk report of the financial statements. Separate reporting in the non-financial section is redundant."]
["Survey","Verband kommunaler Unternehmen e.V.","Business association (other than association of financial institution)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Verband kommunaler Unternehmen e.V.","Business association (other than association of financial institution)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Verband kommunaler Unternehmen e.V.","Business association (other than association of financial institution)","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","ABT Bolagen","Preparer (non-financial preparing a sustainability report)","Sweden","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","ABT Bolagen","Preparer (non-financial preparing a sustainability report)","Sweden","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","It will drive some costs, but fair representation is fundamental."]
["Survey","ABT Bolagen","Preparer (non-financial preparing a sustainability report)","Sweden","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","ABT Bolagen","Preparer (non-financial preparing a sustainability report)","Sweden","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","The wording is vary vague on what the sustainability matter really means. There should be at least a handful examples on what a typical IRO is and what financial effects can occur. That would greatly increase the understandability of non-sustainability proffessionals of understanding the DMA."]
["Survey","ABT Bolagen","Preparer (non-financial preparing a sustainability report)","Sweden","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","The wording is vary vague on what the sustainability matter really means. There should be at least a handful examples on what a typical IRO is and what financial effects can occur. That would greatly increase the understandability of non-sustainability proffessionals of understanding the DMA."]
["Survey","Fairtrade International","NGO","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We welcome the streamlining achieved by reducing overlaps between cross-cutting and topical standards and by reinforcing the role of general disclosure requirements. In practice, many PAT provisions within topical standards have served more as illustrative guidance than as genuine datapoints, so their consolidation is a positive step. We also support the continued use of the five-part environmental and four-part social structures; in earlier feedback we stressed the importance of maintaining comprehensive E and S metrics.  That said, an important gap remains: the S standards do not currently require disclosure of relevant, entity-specific metrics. With S2, S3, and S4 lacking such metrics—and sectoral standards containing them no longer advancing—the responsibility necessarily shifts toward entity-specific disclosure. Making this shift explicit would establish clearer expectations for both preparers and users. Consistent with the Danish Institute for Human Rights' recommendations, we suggest amending SX-4 (targets) to explicitly reference metrics. This adjustment would better align topical standards with the cross-cutting framework, acknowledge that companies already monitor and report social metrics linked to impact management and progress, and strengthen comparability and accountability by directly connecting targets with measurable indicators."]
["Survey","Fairtrade International","NGO","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Fairtrade International","NGO","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","EcoVadis","User (analyst, data provider, rating agency, etc.)","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","While concepts like prevention, mitigation, and remediation are well-understood in due diligence, the ESRS draft creates a challenge by requiring different reporting rules for actual and potential impacts. This can lead to confusion and subjectivity in how companies measure and report on the effectiveness of their actions.  The primary issue is that the option to report on a \"net\" basis for potential impacts can mask a company's true sustainability performance. This approach, while potentially aligning with internal risk management, can lead to a misleading picture for stakeholders. For example, a company with a high-risk operation that has implemented a single, one-off mitigation measure (like a containment wall) might report it as a non-material impact. In contrast, a more proactive company that uses continuous mitigation systems (like constant monitoring) may have to report on a \"gross\" basis, making its risk appear more significant even if it's safer in reality. This discrepancy can create a reporting environment where less-proactive companies appear to have lower risk than those with robust, ongoing management systems.  To address this, we recommend that ESRS 1 indicate clearer principles and more explicit guidance on how companies can apply a \"gross\" or \"net\" approach, ensuring a consistent and accurate representation of their sustainability performance without creating unnecessary burdens."]
["Survey","EcoVadis","User (analyst, data provider, rating agency, etc.)","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Although efforts are being made to increase alignment, some measures negatively impact it. Specifically, it concerns additional ESRS-specific reliefs such as extending the concept of \"undue cost and efforts\" to all metrics, allowing reporting on partial scope, and exclusion of non-material activities from metric calculations if they are not expected to drive impacts, risks, and opportunities (IROs). Additionally, revised ESRS standards allow acquired subsidiaries to be included only from the next reporting period and disposed entities to be excluded from the start of the period, differing from IFRS Standards' immediate inclusion/ exclusion approach. Finally, ESRS simplifications hinder interoperability with ISSB by removing the preference for direct data in value chain metric calculations and eliminating common data points (e.g., the disclosure on gross GHG emissions intensity in ESRS E1 Climate Change). Therefore, more collaborative efforts are expected between EFRAG and ISSB in future phases to advance and not lose interoperability."]
["Survey","EcoVadis","User (analyst, data provider, rating agency, etc.)","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","EcoVadis","User (analyst, data provider, rating agency, etc.)","France","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","A mismatch exists between the objective of disclosing gaps between actual and adequate wages and the proposed methodology for non-EU countries as the adequate wage benchmarks for the EU companies could match a lower national or sub-national minimum wage for the non-EU companies. The methodology asks whether the statutory minimum wage takes into account the ILO wage setting principles under AR 22 b) i). These principles are not relevant to the estimation of living wages. We recommend reviewing Amended AR 22 b i) by: - Referring explicitly to the conclusions of the Meeting of Experts on wage policies, including living wages, instead of the ILO principles. - Removing the second point which refers to the use of Statutory Minimum wage as legal minimum wages are usually substantially below accepted levels of adequate wage or living wage, creating different standards for wage requirements between EU- and non-EU employees, and making the reported information on no-EU employees irrelevant for decision-makers and financial institution. Furthermore, official norms on wages may not be periodically reviewed as per ILO principles, or not adequately adjusted, which will require preparers to conduct additional due diligence for each country where this data point may be used, leading to more bureaucracy and subjective judgement calls to define what are \"accepted\" adjustments. Additionally, we suggest enhancing the AR by adding examples of/references to IDH recognised Living Wage methodologies. As we acknowledge that the access to these databases is not free, we recommend in parallel to make available a free of charge living wage database, in a practical format for data extraction and consolidation."]
["Survey","EcoVadis","User (analyst, data provider, rating agency, etc.)","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Points of concern requiring further improvement:  - fair representation  - undue cost of effort  - reliefs for metrics without time limit and ambiguity  - complexity assessing  remediation, mitigation and prevention"]
["Survey","EcoVadis","User (analyst, data provider, rating agency, etc.)","France","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","NG Nordic AS","Preparer (non-financial preparing a sustainability report)","Norway","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We welcome the clarified structure and the reorganization of the content of the requirements. However, we believe that there is still much room to improve the language of the Standards for better understandability, clarity and simplicity. We would welcome Standards that use less jargon and are more accessible and concise."]
["Survey","NG Nordic AS","Preparer (non-financial preparing a sustainability report)","Norway","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","We agree with all the new mandatory datapoints, except for E5-5. As a waste management company, we believe that traceability of waste shipments and ensuring that waste is treated in a sustainable and environmentally responsible manner, is extremely important. Since the environmental (and social) impact of waste shipments depends on their final destination, the ESRS should be aligned with policies like the EU's Waste Shipment Regulation aiming to ensure that waste is only sent to authorized waste treatment facilities, especially for exports outside the EU/EEA. Thus, companies that have identified E5 as a material topic should be able to ensure that the final destination of waste is known, or at the very least disclose how they will improve knowledge of their waste flows."]
["Survey","NG Nordic AS","Preparer (non-financial preparing a sustainability report)","Norway","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","We strongly believe that the ESRS requirements for reporting waste should be aligned or mapped with the Recovery and Disposal Operations codes outlined in Annex I and Annex II of the Waste Framework Directive (WFD) (Directive 2008/98/EC). Currently it is unclear and open to too much interpretation on whether waste that is thermally treated, either at waste-to-energy plants or high-temperature incineration plants which recover energy and generate electricity and district heating, should be reported as \"other recovery operations\" or \"thermal-based disposal/incineration\").   We suggest the following changes to the section 37-38 in the Disclosure Requirement E5-5 – Resource outflows:  c) the percentage and/or total weight diverted from disposal, with a breakdown between hazardous waste and non-hazardous waste, and a breakdown by the following recovery operation types: i. preparations for reuse;  ii. recycling; and  iii. other recovery operations; (This type should be split into material recovery and energy recovery. The option energy recovery should include recovery code R1 (Use principally as a fuel or other means to generate energy) as outlined in the Annex II of the Waste Framework Directive (Directive 2008/98/EC).)  (d) the percentage and/or total weight directed to disposal with a breakdown between hazardous waste and non-hazardous waste, and a breakdown by the following disposal operation types:  i. thermal-based disposal; (We believe that this type should be reverted back to incineration, and it should only include disposal codes D10 (Incineration on land) and D11 (Incineration at sea) as outlined in Annex I of the Waste Framework Directive (Directive 2008/98/EC)).   ii. landfill; and  iii. other disposal operations)"]
["Survey","Sygris","Consultant (including software vendor)","Spain","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Sygris agrees that Option 1 strikes the right balance in the short term. It maintains decision-useful discipline while acknowledging genuine estimation hurdles. Requiring qualitative context and permitting omission of quantitative figures only when measurement is infeasible or when uncertainty would mislead is an appropriate center of gravity. We also support the explicit exclusion of a \"skills/capabilities\" excuse, which rightly places responsibility on governance and planning rather than resourcing narratives. To avoid open-ended under-quantification, we initially support the idea of a standardized disclosure package whenever quantitative information is omitted, covering: (i) affected financial statement elements; (ii) scope coverage; (iii) reason for non-measurement; (iv) methods considered and why they were rejected; and (v) a time-bounded improvement plan. Safe-harbour language should also apply to forward-looking estimates to encourage good-faith quantification.  That said, we recognize that over the medium to long term this framework could become rigid and bureaucratic. Imposing a full standardized package or improvement milestones in every case may generate little value where uncertainties are structural or estimates are inherently unreliable. More flexibility should be allowed in such cases, limiting disclosure to a clear qualitative explanation of the challenges and the financial areas most affected, without forcing unrealistic commitments or detailed accounts of rejected methodologies. Further refinements include encouraging aggregation or ranges when confidentiality is at stake, permitting sensitivity ranges or scenario-based bands (as in climate DR E1-11) where point estimates are unreliable, and introducing a simple \"estimation status\" taxonomy (separable/estimable; estimable as range; not separable) for consistency with IFRS S1/S2. This approach preserves short-term discipline while ensuring that, in the long run, disclosures remain decision-useful rather than mechanical or low-value."]
["Survey","Sygris","Consultant (including software vendor)","Spain","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","· Minimal structure for targets. Several narrative qualifiers around targets/actions were deleted or shifted to NMIG. Keep the standard lean, but reinstate a compact, mandatory target schema (metric, base year, target year, organisational boundary, whether it covers areas at water risk). This preserves comparability without bringin back the heavy narrative · Location granularity with thresholds. Site-by-site lists were rightly deleted to prevent noise but require a threshold-based location disclosure (e.g., top sites accounting for ≥70–80% of total withdrawal/consumption or any site >10% of total) and a clear flag where metrics relate to high-water-stress areas. Discharge/return pathways flags. Detailed descriptions of projects (e.g., reinjection to aquifers, reuse schemes) moved to NMIG. Add a binary/checkbox line-item for material discharge pathways (to surface water, to groundwater/reinjection, to third parties for reuse) so readers can compare undertakings without wading through narratives. · Explicit cross-references. With ecological thresholds and risk-identification detail deleted from E3, add clear signposts in E3 objectives/DR intros pointing to the relevant ESRS 2 paragraphs and NMIG examples. That operationalises \"report once, reference many\" and reduces accidental omissions."]
["Survey","Sygris","Consultant (including software vendor)","Spain","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","1. We support the overall reduction, but recommend restoring (or explicitly retaining) a minimal backbone of S3 datapoints that every undertaking reports when S3 is material:Grievance mechanism performance: number of community grievances received, % assessed as admissible, median/average days to resolution, and % resulting in remedy. This turns process into performance without pages of narrative. 2. Significant community incidents: count and severity of incidents affecting communities (including security-related human-rights incidents linked to company or contracted security), with a short status field (closed/open) and corrective action flag. 3. Land acquisition/resettlement: number of projects involving involuntary resettlement or economic displacement, households affected, and % compensated/restored to standard—reported only when applicable, with an Indigenous Peoples/FPIC flag where relevant. 4. Community health & safety outcomes: offsite fatalities and serious injuries attributable to company operations (distinct from workforce  H&S), plus a brief indicator of major community health events linked to operations (e.g., spills, releases). 5. High-risk site coverage: % of high-risk sites with (a) a recent impact assessment and (b) a documented engagement plan. One percentage each—no narrative expansion. Support the deletions of: granular demographic cross-tabs that risk re-identification; repetitive descriptions of engagement methodologies; and duplicative environmental impact detail already captured under E-standards."]
["Survey","Sygris","Consultant (including software vendor)","Spain","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","It is positive that EFRAG has sought to align the non-EU methodology with the ILO's 2024 language, as this creates a common vocabulary and steers disclosures toward adequacy rather than mere legality. This is a meaningful advance. Nonetheless, certain gaps remain that could undermine comparability and even encourage under-reporting in cases where statutory minima fall significantly below an adequate wage. To address these shortcomings, several refinements should be considered: · Best available data principle: The hierarchy should prioritize credible living-wage benchmarks instead of treating them as a last resort. Where recognized datasets exist (e.g., national social-partner benchmarks, Anker-type estimates, or peer-reviewed equivalents), undertakings should use them over statutory minima known to be inadequate. If multiple credible sources are available, the one with broader coverage, more recent data, or a higher adequacy threshold should be selected, with disclosure of the criterion applied. · Standardized method flag: To balance transparency with conciseness, each country should be reported through one compact table including: o Method used: statutory minimum / sectoral minimum / recognized living-wage benchmark / modeled proxy. o Coverage: % of employees for whom the method applies. o Outcome: % of employees at or above the adequate-wage threshold (FTE-normalized). This avoids narrative reporting while ensuring comparability. · Normalization and safeguards: Prevent inconsistencies by requiring reporting in local currency with euro translation and disclosure of the exchange-rate basis. Normalize to FTE and standard hours, and specify the reference month/year of the benchmark. Allow banded estimates for small populations and apply a privacy de minimis by suppressing cells with fewer than five employees. Finally, to manage burden, the country selection rule already applied elsewhere (e.g., top countries by headcount) should be used, together with a one-year transitional relief and an \"undue cost or effort\" explanation that outlines a plan to improve data quality."]
["Survey","Sygris","Consultant (including software vendor)","Spain","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification is visible, but comparability depends on tight basics. Keep mandatory tables lean: emissions by compartment (air, water, soil), by substance class/material group, and by unit/threshold with clear references. Avoid site-by-site enumeration unless a hotspot is material; otherwise aggregate to country/region and highlight top contributors. Where screening models are used, disclose data source, coverage %, and a short uncertainty note. Place specialised methodologies (facility-specific models, niche indices) into non-mandatory guidance. I partially agree: the direction is right; the standard should emphasise a common, minimal table structure and resist re-introducing complexity via bespoke lists."]
["Survey","Sygris","Consultant (including software vendor)","Spain","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Value-chain coverage remains challenging. To make this workable and informative: adopt a phased approach prioritising salient risks; require light transparency on data source (primary/estimate/proxy), coverage %, and uncertainty. Encourage sampling strategies in guidance rather than mandating exhaustive mapping. Promote cross-reference to ESRS 2 for governance/process text to avoid repetition. I partially agree: simplification is visible; success hinges on clear, minimal fields for estimate transparency and prioritisation."]
["Survey","Transport & Environment (T&E) ","NGO","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Transport & Environment (T&E) ","NGO","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Transport & Environment (T&E) ","NGO","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Transport & Environment (T&E) ","NGO","Belgium","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Transport & Environment (T&E) ","NGO","Belgium","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","EFAMA","Association of financial institutions","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","EFAMA acknowledges EFRAG's intention to streamline the ESRS architecture. We consider ESRS 2 (general disclosure requirements) as a \"safeguard\" disclosure requirement against materiality-driven omissions, ensuring that cross-cutting governance, strategy, and impact-related information is available even when topical standards are deemed non-material. In line with our response to the public survey, we also welcome the elimination of voluntary disclosure and moving ARs directly under the respective DR to which they correspond.  Nonetheless, we do not support eliminating the requirement to disclose information on whether the undertaking plans to implement a PAT for material topics and timelines, as removing this essential information on how companies intend to address identified sustainability risks and opportunities. Transparency requires explanation when PAT is absent, particularly for material negative impacts and risks. This could lead to weaker comparability for investors, as it may allow companies to state \"no PAT\" at the topic level without explaining where gaps remain and how they intend to address them.    We urge the introduction of an \"explain if not\" approach, where undertaking should disclose why PAT has not been developed for material risks and negative impacts, distinguishing these from opportunities where PAT may be less critical. This maintains accountability without excessive prescription, ensuring that the absence of PAT represents a deliberate strategic choice rather than an oversight. Transparency in risk management decisions is essential for maintaining stakeholder confidence and ensuring comparability between undertakings"]
["Survey","EFAMA","Association of financial institutions","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","EFAMA","Association of financial institutions","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","EFAMA suggests that the consolidation of datapoints and the removal of overlaps can improve readability and reduce duplication for reporting entities, provided that investor use-cases under SFDR remain fully supported. In light of the upcoming SFDR revision, the revision of Annex I PAIs is also under consideration. It is crucial that sustainability-related disclosures under the SFDR rely on available reported data from undertakings under the CSRD. In the meantime, EFRAG should ensure that it retains within the ESRS all datapoints corresponding to the 14 mandatory PAIs. These indicators are essential for the functioning of the SFDR and must remain fully available to users of sustainability disclosures."]
["Survey","BNP PARIBAS BANK POLSKA S.A.","Bank","Poland","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","In my opinion this is a good direction of standardization towards IFRS S1/S2, it is worth monitoring and documenting which simplifications may negatively affect interoperability."]
["Survey","BNP PARIBAS BANK POLSKA S.A.","Bank","Poland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","as above."]
["Survey","Fabasoft AG","Preparer (non-financial preparing a sustainability report)","Austria","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree"]
["Survey","Fabasoft AG","Preparer (non-financial preparing a sustainability report)","Austria","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Fabasoft AG","Preparer (non-financial preparing a sustainability report)","Austria","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Fabasoft AG","Preparer (non-financial preparing a sustainability report)","Austria","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Fabasoft AG","Preparer (non-financial preparing a sustainability report)","Austria","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Henkel partially agrees with the proposed amendments. Several changes, such as the clarification of the DMA approach, the relationship between impacts, risks, and opportunities, and the emphasis on ESRS as a fair presentation framework are constructive and align with our current practices. We also welcome the allowance to include non-material topics, provided material information is not obscured, though further guidance would be helpful. Additionally, clarifications around aggregation and disaggregation levels are noted. However, certain amendments raise concerns. The increased emphasis on materiality as a general filter (par. 21(a)) may lead to additional compliance efforts and extended auditor discussions especially on what is considered as \"necessary for users …to understand\". We expect this to result in an expansion of the information to be provided and would strongly recommend maintaining the focus on \"decision usefulness\" rather than mere stakeholder interest \"to understand\"."]
["Survey","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We agree with the proposed relief for lack of data quality on metrics, as it offers a practical solution by allowing partial disclosures with improvement plans, supporting flexibility without compromising transparency. Forcing the collection of weak data does not contribute to high-quality reporting or comparability."]
["Survey","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Henkel partially agrees with the proposed reduction in datapoints. However, as many requirements have merely been merged or aggregated into a single disclosure requirement, the actual reduction in reporting requirements is lower than the reduction in the number of data points may suggest. Based on a detailed analysis of our current report, most of the disclosure requirements would remain for us and we expect a net reduction of only 10-15%. However, we do acknowledge the reduction efforts, particularly in MDRs/GDRs and the avoidance of duplications between ESRS 2 and topical chapters."]
["Survey","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","We agree on keeping a disclosure on the gender pay gap. However, information on the unadjusted pay gap is not informative. This is because the formula does not consider the tasks and responsibilities of the employees at all and therefore, one cannot derive any statement on equal pay for work of equal value. To be able to make a meaningful statement, the cost of living in the different countries and the comparability of responsibilities should at least be considered."]
["Survey","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We are critical of the inclusion of Substances of Concern (SoCs) in the ESRS. These substances often overlap with existing categories such as Substances of Very High Concern (SVHC), leading to double counting and inconsistent data. Without a clear hazard category hierarchy, reporting on SoCs adds unnecessary complexity without delivering additional value. For example, orange oil is skin sensitizing and a chronic hazard to the aquatic environment category. For the sake of simplification and consistency, SoCs should not be included as a general requirement for all stakeholders."]
["Survey","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","ecoDa","Other","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","ecoDa","Other","Belgium","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","ecoDa","Other","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","ISEAL","NGO","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","ISEAL welcomes burden reliefs, especially for SMEs. We recommend that ESRS explicitly recognise the role of credible VSS in reducing reporting burdens. By sourcing products and services certified to credible VSS, companies—especially SMEs—can rely on the VSS's assurance mechanisms and data, reducing the need for costly, duplicative verification. Policymakers should incentivise or recognise the use of credible VSS to meet ESRS requirements efficiently and credibly. See the technical notes above about relevant sections of the ISEAL Code and Credibility Principles."]
["Survey","ISEAL","NGO","United Kingdom","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","ISEAL encourages EFRAG to recognise the value of credible VSS linked to the Global Living Wage Coalition (GLWC) (https://www.globallivingwage.org/) work on definitions and methodology for providing wage data and approaches, especially in non-EU contexts where data availability and comparability are challenging. GLWC provides a ready-to-implement answer to EFRAG's specific problem. VSS often have established, multi-stakeholder processes for defining and verifying living wage benchmarks, which can support companies in meeting ESRS wage disclosure requirements. VSS offer more than just data; they provide a field-tested, multi-stakeholder-vetted methodology for defining and verifying living wage benchmarks. By referencing these methodologies, EFRAG can provide a credible, practical solution to a complex data point, ensuring both transparency and comparability. There may be a willingness on the part of VSS to field test."]
["Survey","Ministry of the Economy of Luxembourg","Public authority","Luxembourg","22.E5.","Comments on deleted datapoints in ESRS E5","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","KEEP mandatory:  E5 - composition/resource inflows E5 - hazardous substances breakdown of waste E5 - quantitative disclosure of product reliability, durability and upgradeability E5 - quantitative indicators on resource recovery and secondary raw material use"]
["Survey","Ministry of the Economy of Luxembourg","Public authority","Luxembourg","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Ministry of the Economy of Luxembourg","Public authority","Luxembourg","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","Ministry of the Economy of Luxembourg","Public authority","Luxembourg","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","The inclusion of ARs directly after the relevant requirements is of great help to improve the understanding of the requirements.  We did not feel that may and non-voluntary requirements in the previous version of the ESRS was unclear but we acknowledge that deleting them will make which requirements need to be met crystal-clear."]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","Requirements are mostly manageable. However, we would like to point out that the location of key assets may be considered sensitive information and thus difficult to provided (i.e. due to national security reasons etc.).",null,null,""]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","The consolidation of IRO requirements under ESRS 2, instedad for repeating them in the standard, may clarify that it is not necessary to repeat the content under each standard but it does not reduce the acutal amount of work (without acting on the rerquired content to address the requirement)."]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","Undertakings should already follow the information required in S1 in one way or another and thus it should not require such a big additional effort.   An undertaking's own workforce is the most crucial part of it, as there would not be any work done without it, thus the information regarding the own workforce be complete not matter if that means having to disaggregate the data into several lines."]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Trafikförvaltningen, Region Stockholm","Preparer (non-financial preparing a sustainability report)","Sweden","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Royal Hollway University of London","Academia","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","This is an improvement."]
["Survey","Invest Europe","Association of financial institutions","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","We support the intent to simplify \"anticipated financial effects\", especially through the removal of the acute/chronic split and the streamlined datapoints.   At the same time, we are concerned about the removal of explicit time horizon references (short, medium, and long term), which creates a misalignment with IFRS S2 (paragraphs 16(c)–(d)). IFRS expects entities to disclose how their financial position, performance, and cash flows are expected to evolve over time, including through capital expenditure, divestments, and financing strategies. Without these time-based anchors, ESRS disclosures risk hindering interoperability for companies subject to both CSRD and global frameworks.   Moreover, the addition of forward-looking information on potential liabilities that do not yet meet accounting recognition criteria goes beyond IFRS S2, which does not explicitly mandate disclosure of such liabilities, and may require further clarification to ensure consistent interpretation and assurance.  We recommend reintroducing time horizon framing (short, medium, and long term) to align with IFRS S2 and improve the clarity and comparability of anticipated financial effects disclosures.",null,null,""]
["Survey","Invest Europe","Association of financial institutions","Belgium","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Invest Europe","Association of financial institutions","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We are broadly supportive of the direction the ESRS amendments are taking, the changes show real progress on simplification, interoperability, and usability, and we recognize the effort that has gone into getting here.  That said, we want to stress one important point: PE/VC simply do not operate like corporates, and this difference really matters when it comes to reporting. PE/VC fund managers work through capital allocation into portfolio companies, without direct operational control, and within fund cycles and lifespans that are very different from a corporate's ongoing business model.  If these differences are not acknowledged consistently, there is a real risk that requirements push PE/VC firms to produce disclosures that are burdensome, speculative, or duplicative – without giving investors and other stakeholders the clear, meaningful, decision-useful information they actually need.   We acknowledge that EFRAG has tried to address this in certain areas, but the issue remains broader, and it needs to be kept in view across the board. That was true before the Sustainability Omnibus, and it remains true now. We encourage EFRAG to integrate this distinction systematically as adjustments are considered."]
["Survey","Value Balancing Alliance","Business association (other than association of financial institution)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Maintaining mandatory disclosure of financial effects ensures interoperability with the ISSB's IFRS S1 and S2 standards, which also require companies to disclose material financial impacts of sustainability-related risks and opportunities. This alignment is crucial for multinational companies and global investors, as it reduces duplication, facilitates cross-border comparability, and a consistent global sustainability reporting system."]
["Survey","Sphera Solutions, Inc.","Consultant (including software vendor)","United States","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Option 1 best balances flexibility with investor-useful information and aligns the ESRS architecture with established practice. It keeps quantitative disclosures as the default for anticipated financial effects, but builds in targeted relief when (i) effects are not separately identifiable or (ii) measurement uncertainty is so high that numbers wouldn't be useful—while still requiring qualitative explanation and, where possible, combined quantitative effects.  This relief is anchored in reasonable and supportable information without undue cost or effort (ESRS 1, p.20, ¶87–¶89), and it allows use of ranges when quantifying (ESRS 2, p.12, AR 18).  Two improvements would strengthen comparability and assurance without undermining the relief:  1)Minimum transparency package when omitting quantification: require (a) the sign and direction of effects, (b) the time horizon, (c) the financial statement line items likely affected, and (d) a coverage ratio (share of material IROs/topics included vs. excluded), plus the reason for non-quantification per Option 1(c). (ESRS 2, p.11, ¶23(c)).  2)Method anchor and progress: require a short bridge to plans and funding (investment/disposal plans; funding sources) when discussing anticipated effects (ESRS 2, p.12, AR 16), and allow/encourage ranges with key assumptions and uncertainties (ESRS 1, p.19, ¶85(b)–(c); ESRS 2, p.12, AR 18). Finally, Option 1 avoids an undue loss of information inherent in Option 2 (qualitative-only), while still accommodating confidentiality via existing sensitive information provisions where needed (ESRS 1, p.22, ¶98–¶101). Phase-ins already provide ramp-up time (Appendix D, ESRS 1, p.33–34).  On balance, Option 1, with the transparency tweaks above, delivers decision-useful, comparable reporting without imposing impracticable burdens."]
["Survey","Sphera Solutions, Inc.","Consultant (including software vendor)","United States","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We agree that the new datapoints are justified and provide enhanced interoperability  with other existing frameworks like Eco-design for Sustainable Product Regulation and Critical Raw Materials Act."]
["Survey","Sphera Solutions, Inc.","Consultant (including software vendor)","United States","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Pacific Institute","NGO","South Africa","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Working through S1 and S2 previously was repetitive. Merging them is simpler."]
["Survey","Pacific Institute","NGO","South Africa","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","I remain confused about the distribution of some topics across the standards. One example is brine and concentrate from reuse and recycling of water. Do the savings of these processes get recorded solely under E3, or also in part under E5? And where does brine get dealt with? Under E2 or E5? More clarity would be welcomed.  Specific load is now omitted, diverging the standard more from water quality guidelines in, e.g. NPWI, the water footprint network and the Water Quality Benefit Accounting guidelines."]
["Survey","ETUC","Trade union","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The \"may\" (voluntary) data points should not be eliminated. In many cases they are \"shall\" in GRI standards, so it is important to keep them to align with GRI standards. Also, many of them were originally proposed as mandatory by EFRAG to the EC. The first wave of reports show that many companies have reported some \"may\" data points. Retaining them would help ensure standardization/comparability between company reports. Almost all of the datapoints for non-employee workers are voluntary, thus most datapoints for this vulnerable group of workers has been lost. Also, important datapoints on full time versus part time workers has been eliminated."]
["Survey","ETUC","Trade union","Belgium","22.S1","Comments on deleted datapoints in ESRS S1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","The reduction in the number of mandatory and voluntary datapoints goes far beyond striking an acceptable balance. As mentioned above, the voluntary datapoints should be maintained to provide alignment with GRI, which is currently in the process of strengthening its labor standards, as well as guidance and standardization for companies reporting more than just the mandatory datapoints. An explicit quantitative goal of 50%+ reductions was never set by the European Commission for EFRAG. A number of S1 datapoint metrics have been eliminated which should be reinstated:  •\tS1-5 Employees: gender breakdown for zero-hour employees •\tS1-8 Diversity: age distribution; •\tS1-10 Social protection: reinstatement of retirement  •\tS1-12: Training and development: gender breakdowns, •\tS1-13 Health and safety: fatalities from ill-health for non-employees and other workers on site; •\tS1-14 Work-life balance: employees that took family related leave;"]
["Survey","ETUC","Trade union","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","The unadjusted gender pay gap should be kept as mandatory, since the methodology for calculating it is clear. The adjusted pay gap figure as voluntary. In practice many companies are reporting both figures, which is useful for improved transparency. However, since the methodology for calculating the adjusted figure is not standardized, the unadjusted should be kept mandatory."]
["Survey","VDMA","Business association (other than association of financial institution)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","- ESRS 1 29: does this mean that an issue can be assessed as not material in the following year and therefore no longer needs to be reported? How can this be argued to the auditor or where is the consistency of the report? - There is still confusion regarding ESRS 1 46/47 vs. ESRS 1 26: What does it mean that not every IRO has to be assessed? ESRS 1 26 states that you should start with the identification of impacts and assess them. In ESRS 1 46/47: top-down is sufficient.  Only in AR 17 for para 48(a) are the two options + clarify possible paths, sections previously confusing - ESRS 1 44: does this make sense? Or are these not dependencies - if I take measures that avoid a risk but have a negative impact on something else? - ESRS 1 AR 11 for para 33: what does \"appropriate level\" mean? - ESRS 1 70: Is this not a double designation: once for the reporting entity and once for the lessor. - A definition of the scale of likelihood or generally pre-defined scales would be helpful. There still seems to be room for interpretation which will result in discussions with auditors. Clearer definition of when an information is \"necessary\" needed.  - Unclear how to examine the new S-Subtopics with the former sub-sub-topics in brackets. - Who is the relevant user of a report? This should be defined. Who can decide what's material? The power of the user to determine materiality in any case is not the right approach! It's the company, who has the main knowledge!  - DMA- sub-sub topics. Not sure, if the deletion is really helpful. Flexibility in case of DMA-analyses on topic-level, sub-topic-level or sub-sub-topic level would be a better approach."]
["Survey","VDMA","Business association (other than association of financial institution)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Overall, we appreciate the previously introduced reliefs and acknowledge their positive impact. However, we have some reservations regarding the newly proposed relief for acquisitions and disposals. We recommend removing paragraph 73 of ESRS 1 and retaining only paragraph 72. Rationale: Paragraph 73 introduces an additional differentiation for major acquisitions and disposals, which unnecessarily complicates the application of the relief. In contrast, paragraph 72 alone offers a clear and practical simplification that would be genuinely helpful for preparers."]
["Survey","VDMA","Business association (other than association of financial institution)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","Groentenfruit Huis","Business association (other than association of financial institution)","Netherlands","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree"]
["Survey","Groentenfruit Huis","Business association (other than association of financial institution)","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Groentenfruit Huis","Business association (other than association of financial institution)","Netherlands","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","Crédit Agricole","Bank","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Materiality assessment:   - In general, we support the simplification and amendments proposed by EFRAG. Nevertheless, all proposals made by EFRAG are not clear at this point:    - Paragraph 48(a) of ESRS 1, implies that undertakings are allowed to \"derive\" the materiality of certain topics without DMA. This paragraph is not coherent with part 3.3 on the double materiality assessment and would result in divergent interpretations.    - Paragraph 48(b) implies that when an undertaking thinks that IROs are \"likely\" to be material \"limited assessment\" is enough, what does that mean? Is DMA required in those case? How to define \"likely\"?    We advise EFRAG to clarify this paragraph.    Filter of materiality:   - ESRS 2 is now subject to a filter of materiality, as preparator, we do not support this change, as ESRS 2 requires essential information to understand the sustainability reporting of our counterparties and stakeholders (scope of the reporting, time horizon used...). If we do not have key information regarding the basis of preparation of sustainability reporting, it will limit our understanding and the relevance of these reports.   Moreover, we do not understand how to apply this concept to several of the DR included in ESRS 2, for example the basis for preparation (BP 1 et BP 2) or the DR that requires undertaking to disclose their methodology (IRO 1).    We advise EFRAG to take into account these considerations.    Crédit Agricole agrees  with proposed simplification which is not changing the methodology regarding the double materiality analysis,  in order to guarantee the permanence of information and to ensure the comparison of disclosures for all banks and firms."]
["Survey","Crédit Agricole","Bank","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Anticipated financial impact should not be subject to compulsory public disclosure. Data that is highly dependent on estimates and subject to significant uncertainty does not provide reliable insights for investors or other users, due to its potential variability. Premature disclosure of such information may not only mislead stakeholders but also expose companies to reputational and legal risks associated with misinterpretation.  Reputational risk: To date such data would be considered as strategic and while we do take into account financial aspects of such risk and improve our methods of estimation, risk frameworks we consider that the level of reliability is still to be improved in particularly for such long-term time horizons where there is high uncertainty.  Strategic risk: Some of such long-term data would expose the strategy of the group. Risk of inconsistency and methodological aspects: There are no methodological cross industry standards for such calculation. We consider that some of them do not make sense for financial institutions. Furthermore methods are being shared and discussed with supervision as to the expectations and granularity levels."]
["Survey","Crédit Agricole","Bank","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We believe biodiversity and ecosystem targets can be better tailored to make these ARs more practical and relevant for diverse businesses. Currently, AR26 only addresses site-based biodiversity goals aimed at restoring ecological integrity, overlooking non-site-specific actions. This limits the AR in two ways: 1) it excludes corporate-level biodiversity targets important for large companies and financial institutions, and 2) it misses the chance to have companies set targets to reduce their negative impacts on biodiversity, such as the five pressures outlined by IBPES.  Target-setting should reflect each company's business activities. Financial institutions differ from other sectors, as their main impacts are linked to financing and investments activities, usually at the counterparty level (clients or issuers). Due to the lack of common biodiversity impact indicators, financial institutions should start with \"process-based targets\", following guidance from UNEP FI PRB Nature Target Setting (2023) and the Finance for Biodiversity Pledge, both aligned to the Global Biodiversity Framework (GBF). Corporates are encouraged to set site-specific targets, distinguishing between overall corporate goals (process-related targets) and site-specific targets based on the mitigation hierarchy.  We also do not understand why references to the GBF were removed from this consultation process. Companies, especially those that operate internationally, should be able to rely on both on national and international frameworks to set biodiversity-related targets."]
["Survey","European Work Council AF-KL group","Trade union","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Double materiality is essential and must remain at the heart of the ESRS framework and European Union sustainability regime for corporate reporting to be credible and useful.  The principle of \"materiality of information\" is concerning since it introduces a further filter for companies to not report information. For example, it represents a step backwards from ID-177, which says that most S1 metrics must be reported if S1 Own Workforce is material. It is essential to maintain the principle of fair presentation in the reporting standards.  It is positive that the revision of the AR 16 list of topics has maintained all of the sub-subtopics for S1 + S2. These are based on the list of social topics in the CSRD and should all be maintained. The emphasis on aggregation (as opposed to disaggregation) is concerning, as disaggregated information (both site-specific and country-specific) is key to understanding the distribution of IROs."]
["Survey","European Work Council AF-KL group","Trade union","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material. Reporting on financial effects is crucial to achieving the objective of putting sustainability reporting on the same level as financial reporting and integrating both. The European Union has recognised the value of a double materiality approach to corporate reporting which requires disclosure of both material environmental and social impacts, risks and opportunities as well financially material data, It is important to keep the requirement on businesses to analyse and understand the financial effects of their business model. This will ensure investors have access to credible data as well as providing the underpinning for future business planning."]
["Survey","European Work Council AF-KL group","Trade union","France","22.E1.","Comments on deleted datapoints in ESRS E1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","•\tS1-5 Employees: gender breakdown for zero-hour employees •\tS1-8 Diversity: age distribution; •\tS1-10 Social protection: reinstatement of retirement  •\tS1-12: Training and development: gender breakdowns, •\tS1-13 Health and safety: fatalities from ill-health for non-employees and other workers on site; •\tS1-14 Work-life balance: employees that took family related leave;"]
["Survey","European Work Council AF-KL group","Trade union","France","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","The unadjusted gender pay gap should be kept as mandatory, since the methodology for calculating it is clear. The adjusted pay gap figure as voluntary. In practice many companies are reporting both figures, which is useful for improved transparency. However, since the methodology for calculating the adjusted figure is not standardized, the unadjusted should be kept mandatory."]
["Survey","BSR","Business association (other than association of financial institution)","United States","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","BSR","Business association (other than association of financial institution)","United States","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","BSR welcomes the introduction of certain reliefs and efforts towards interoperability, particularly the alignment with IFRS S1 and S2 through the \"undue cost or effort\" exemption. These provisions acknowledge the practical challenges companies face in gathering complete and reliable data across their operations and value chains, and they should provide meaningful relief to preparers. The explicit option to rely on estimates or proxies, as opposed to direct data, where appropriate also reflects a pragmatic, principle-based approach that may reduce unnecessary burden.  At the same time, our member discussions have underscored important risks. While reliefs are helpful, their extensive use could undermine the credibility and comparability of disclosures. For instance, allowing partial scope reporting for metrics due to lack of data quality is useful in practice, but it may discourage companies from investing in improved data collection systems over time.  At the same time, stakeholders highlighted the importance of flexibility with respect to calculation of  GHG Emissions. For example, the GHG Protocol accepts three boundary approaches—equity share, financial control, or operational control—and many companies expressed strong preference that ESRS continue to recognize all three. Prescribing only financial control would place unnecessary burden on companies that have applied flexibility allowed in other standards. Similarly use of  wording \"shall consider\" is welcomed in allowing companies to reference the GHG Protocol or ISO 14064 without rigidly following them line by line."]
["Survey","BSR","Business association (other than association of financial institution)","United States","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We encourage EFRAG to refer to BSR's publication Insights Plus issued in September 2025 and entitled ESRS Revisions Mark a Turning Point Toward Principle-Based Reporting, With Open Questions. It can be found here: https://www.bsr.org/en/sustainability-insights/insights-plus/esrs-revisions-mark-a-turning-point-toward-principle-based-reporting-with-open-questions"]
["Survey","Carbone 4","Consultant (including software vendor)","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","Agree : this modification allowing more flexibility on scopes is in line with companies' feedback on difficulty to collect data on all scopes for every metric.   Disagree :  - The need to mention the scope covered by each metric or analysis should however be specified clearly in the paragraph with a sentence like: \"Any exclusion shall be documented / justified.\" - Add a sentence explaining that data collected directly from counterparties shall prevail over estimates - (AR 28 for para 67) For some companies, IROs occur mainly on upstream or downstream value chain, not on direct operations (e.g. land use impacts associated to upstream deforestation for a paper producer). Making metrics disclosure not mandatory for all topics by default seems not relevant."]
["Survey","Carbone 4","Consultant (including software vendor)","France","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","E1-4 - Policies:  - Carbone 4 suggests to mention climate adaptation and climate mitigation in policies (not only in E1-5 on actions).  E1-5 - Targets:  - Disagree: Reference to 2030 and 2050 time horizon has been deleted. Without mentioning time horizons, companies might only set targets from one year to another without defining a real pathway. Carbone 4 suggests to add: \"Undertakings shall define climate targets in the medium and long terms.\" (no need to specify specific years like 2030 and 2050). - Agree: Maintaining this reference to 1.5°C pathway is absolutely key.  E1-7: - Agree: identifying activities in high climate sectors vs. other activities and associated energy consumptions was very painful (or impossible) for companies. - Disagree: table template for disclosing on energy consumption deleted. This table was useful to companies to have guidelines and directly copy-paste the table. - Disagree: not mandatory to calculate the energy intensity ratio. Carbone 4 suggests to make mandatory disclosure of physical intensity ratios (e.g. in tons of products).  E1-8: Disagree: AR 27 for paras. Replace \"may\" by \"shall\" concerning presentation of comparative information."]
["Survey","Carbone 4","Consultant (including software vendor)","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","Agree: the principle of \"fair representation\", derived from financial accounting, is necessary to avoid greenwashing."]
["Survey","Carbone 4","Consultant (including software vendor)","France","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See above"]
["Survey","FBF","Association of financial institutions","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","This topic should be deleted.  The interpretation of the \"fair representation\" principle and the auditing process that would be used are unclear. Overall, this principle in its current version creates an additional burden rather than simplification."]
["Survey","Society for Corporate Governance","Business association (other than association of financial institution)","United States","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","The Society respectfully requests EFRAG clarify and revise three aspects of its proposed approach to (1) permit companies to consider the effect of all mitigation and prevention actions taken during a reporting year when assessing the materiality of potential negative impacts for that same reporting year; (2) permit companies to take mitigation and prevention actions that require significant ongoing efforts into account when assessing materiality; and (3) to avoid any ambiguity, expressly permit consideration of mitigating and preventative actions when assessing financial materiality.  In that the word limits in this survey tool (Parts 2 and 3) won't accommodate our full response to this question, we detailed the above points in our concurrently submitted comment letter to EFRAG."]
["Survey","Ceres","NGO","United States","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The \"undue cost or effort\" relief for identifying material impacts, risks and opportunities is concerning, because this is a crucial phase of the corporate sustainability risk assessment process and should not be shortchanged. For example, Ceres' Roadmap 2030 discusses key elements of that process. We recommend that companies develop and articulate a clear business case for sustainability by actively considering sustainability issues through different lenses, including risk mitigation, cost savings, increased resilience, improved growth, workforce attraction and retention, consumer loyalty, innovation and license to operate, among others. To do this, it is important that companies regularly engage with and consider the perspectives of all key stakeholder groups in the evaluation of material and salient sustainability impacts, and then integrate material and salient priorities in their determination of corporate purpose, evaluation of enterprise risk, refinement of corporate strategy and identification of business priorities. See https://roadmap2030.ceres.org/.  We suggest the following change to address this concern. The draft states that information used in preparing financial statements, operating its business model, etc. \"is considered available . . . without undue cost or effort.\" See Draft ESRS E1: General Requirements, section 3.5. Practical considerations in determining the material impacts, risks and opportunities and their related topics to be reported, para. 47. Similarly, the draft should make clear that the \"usual internal and external sources of evidence\" used for a materiality assessment, including important inputs like engagement with affected stakeholders and experts' engagement, should be considered available without undue cost or effort for identifying material impacts, risks and opportunities. See Draft ESRS 1, section 3.3. Double materiality assessment, para. 27. This would help ensure that companies undertake an adequate sustainability risk assessment process."]
["Survey","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We support the removal of the duplicative requirements that existed in the MDRs and PATs in the original ESRS.  GDR-Actions – Requesting financial/other resources allocated to key actions is not very value adding. It does not say anything about the potential outcome or effectiveness. Stakeholders are likely to care more about the outcome than amounts spent.  Comparability/materiality - the term \"significant\" is not defined. Companies operate in different contexts (size, industry, geography), so X million in one case may be negligible, but in another it may be transformative. There may also be challenges related to scoping what to include (or not) given indirect contributions to an action, collaboration with others, etc.  We suggest focusing sustainability reporting on material impacts and descriptions of main actions. Detailed allocation of financial resources should be more for internal management than an external indicator of sustainability performance.  GDR-Metrics – We suggest removing paragraph 41 b. Requiring the specific environmental conditions and characteristics of the area where the impact is occurring for environmental metrics may be labour-intensive, challenging and provides little additional insight. It imposes a disproportional burden on companies without significantly improving the value of the reporting.  GDR-Targets – Please consider placing the target requirements before actions and resources. We believe it is a more natural order of disclosures in a sustainability statement to present the targets/ambitions first and then disclose actions and resources responding to these.  Target Base Year adjustments - ESRS 1, Para 84(c) requires adjusting the base year of the target following a major acquisition or disposal. Acquisitions or divestments might be part of the business strategy to achieve the target, so the base year should not necessarily be changed. Additionally, this is a behavioural requirement, which contradicts ESRS 1/Para 5 about not mandating behaviour. We recommend making this a voluntary requirement."]
["Survey","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I disagree"]
["Survey","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","General comment across all standards: While there is a reduction in the number of mandatory datapoints, it remains to be seen how much the reporting burden will actually be reduced. Simplifications and streamlining have made several requirements easier to understand. Flexibility introduced in how information is presented in the sustainability statement will likely improve the process of presenting the information. And the relief allowing for exclusion of joint operations over which the undertaking does not have operational control from the calculation scope of environmental metrics will reduce efforts needed to get data from partner companies.   However, in practice we believe the overall reporting burden is unlikely to change significantly. The requirements removed are largely the least important, including many of the narrative based DRs. Quantitative datapoints have been prioritized and many of the underlying metrics and data remain the same."]
["Survey","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See feedback in part 3."]
["Survey","Confindustria","Business association (other than association of financial institution)","Italy","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","In general, PATs have been simplified and we agree on the main changes. However, ESRS 1 Paragraph 84(c) requires adjusting the base year of the target following a major acquisition or disposal. Firstly, this constitutes a behavioral requirement, which contradicts Paragraph 5 stating that \"the ESRS do not mandate behavior but set Disclosure Requirements[...]\". Secondly, it is inconsistent with the possibility of investments or divestments being part of the business strategy to achieve the target. ESRS 2 AR 35 the disclosure on resources allocation (in particular, capital expenditure and operating expenditure) should be \"may\"."]
["Survey","Confindustria","Business association (other than association of financial institution)","Italy","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","In general, we agree with the improvements performed. To further clarify it is better to eliminate all the unclear terms like \"shall consider\" in particular as shall refers to a mandatory action and consider more an optional step, leaving the way forward up to interpretation. This is important in order not to create confusion and avoid misunderstandings with the auditors."]
["Survey","Confindustria","Business association (other than association of financial institution)","Italy","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","While the concept of fair presentation is well-established in financial reporting, its boundaries are far less defined in the context of sustainability reporting, especially considering the double materiality principle that requires to take into account a multi-stakeholder approach compared to the single/financial materiality perspective. The main issue related to a shift from a compliance-based approach to a fair presentation regime is the potential increase in the accountability of Board members regarding the Sustainability Statement, as they should ensure not only consistency with standards, but also demonstrate that information is presented in a manner that is fair to all relevant stakeholders. This creates a gray area, increasing the risk of litigation if stakeholders dispute the adequacy of the information provided. Such a regime, as confirmed also by audit firms, could also complicate their review process, especially considering the lack of a common European standard for sustainability review. The possible solution could be the removal of all the references to fair presentation introduced by EFRAG in ESRS 1 (paragraphs 16, 17, 18), and also in the other standards, if any, and the clarification that the objective of the sustainability reporting is to ensure the compliance with the provisions of CSRD and of ESRS."]
["Survey","Confindustria","Business association (other than association of financial institution)","Italy","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Confindustria","Business association (other than association of financial institution)","Italy","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Regarding environmental topics, both ESRS E2 and E4 raise concerns due to the level of detail required and the potential for excessive disaggregation. These requirements could result in disproportionate reporting efforts, especially for large companies, and may not yield meaningful insights for stakeholders. For detailed feedback please look at the excel file."]
["Survey","Fair Finance Guide Germany","NGO","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Some reliefs are not helpful and rather create confusion and might lead to missing material information or to diverging reporting practice.  The relief \"undue cost or effort\" focuses only on reporting burden for companies, while omitting sustainability impacts and risks. It is very likely that some companies will avoid reporting on material information which they think would be costly or complicated. This could lead to misreporting and hinder standardization and comparability.   Moreover, the relief that allows unconditional exclusion of data from joint operations where the entity lacks \"operational control\" could lead to omitted material information. If the environmental metrics concerning such operations are material, then they should be disclosure. Even when companies lack operational control they usually can obtain data through financial control or influence over the operator.   Furthermore, relief on anticipated financial effects would hinder the integration of transition risks in financial planning. Quantifying financial effects is uncertain, but \"what doesn't get measured, doesn't get addressed\". Quantitative disclosures of these risks are highly relevant.  Finally, the relief on the possibility to increasingly rely on estimates instead of direct data will probably reduce measurement of material data. If gathering direct data is possible, it should be the preferred option to ensure data accuracy."]
["Survey","Fair Finance Guide Germany","NGO","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","We do not agree with the proposed change since it is not in line with the ILO position on living wages. The change would undermine the objective of ensuring living wages and would be more complex for companies since it would require companies to assess countries minimum wages themselves."]
["Survey","Fair Finance Guide Germany","NGO","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We disagree with some reliefs (see question 17)."]
["Survey","Fair Finance Guide Germany","NGO","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Wikirate International e.V.","Other - please specify (required)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The relief allowing partial‑scope reporting when data quality is lacking recognises current data limitations, particularly in value chains. Nevertheless, Wikirate is concerned that no time limit could perpetuate incomplete reporting. We recommend including a sunset clause or at least requiring companies to set a target date for full coverage and to disclose progress annually. The absence of reliable data should not be used to avoid reporting; instead, companies should provide estimations with clear methodologies and commit to improving them. Data disclosed under this relief should still be presented in a machine‑readable format to enable tracking of improvements over time."]
["Survey","Wikirate International e.V.","Other - please specify (required)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Quantitative disclosures of anticipated financial effects (e.g., investments, capex, opex related to sustainability) are crucial for investors and civil society to assess the financial materiality of sustainability impacts and to detect greenwashing. Option 2 would make quantitative reporting voluntary, leading to inconsistent and incomparable disclosures. We therefore support Option 1 but urge EFRAG to narrow the circumstances under which quantitative information may be omitted and to require disclosure of estimation methodologies. Data should be provided in formats compatible with XBRL tagging."]
["Survey","Wikirate International e.V.","Other - please specify (required)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Given the fast‑evolving landscape for biodiversity metrics, reviewing and updating AR 26 to align with science‑based frameworks like the Science Based Targets Network (SBTN) is essential. Clearer guidance on setting and disclosing biodiversity targets will improve comparability and encourage companies to adopt ambitious, measurable objectives. Wikirate suggests including quantitative indicators such as area protected or restored, number of sites with approved ecological integrity, and species recovery metrics. Guidance should emphasise digital reporting and data‑tagging to support analysis."]
["Survey","Wikirate International e.V.","Other - please specify (required)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Wikirate International e.V.","Other - please specify (required)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","PKF Consult Spółka z ograniczoną odpowiedzialnością Sp. k.","Auditor","Poland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","The proposed amendments may lead to a lack of comparability across sustainability reports and reduce the pressure on companies to advance their sustainability transition. This, in turn, could hinder progress toward achieving the objectives of the EU Green Deal."]
["Survey","PKF Consult Spółka z ograniczoną odpowiedzialnością Sp. k.","Auditor","Poland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Accountancy Europe","Auditor","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We suggest reinstating the requirement to cross-reference with the financial statements in ESRS 1 pa114 as the proposed optionality impairs connectivity and contradicts Articles 19a/29a of the CSRD. This is key for regulators, investors, and other stakeholders. The current proposal hinders users' understanding of the connections of the 2 statements. Moreover, it creates divergence with the ISSB standards.  We appreciate the ESRS now allow for an Executive Summary, Appendices and sections with information material only to certain users. However, we call for clarifications on how to prepare them, including how to ensure fair presentation (of IROs) and avoid greenwashing. EFRAG could also provide an example of how and where in the sustainability statement these elements could be found, noting that if these elements are provided, they will be subject to the same (digitalisation, assurance) rules as the other part of the ESRS. Regarding Appendices, we call for clarifications as to what type of information would be best suited for an Appendix versus in the main body of the sustainability statement."]
["Survey","Accountancy Europe","Auditor","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Global Unions' Committee on Workers' Capital","Trade union","Canada","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Double materiality is essential and must remain at the heart of the ESRS framework and European Union sustainability regime for corporate reporting to be credible and useful. The principle of \"materiality of information\" is concerning since it introduces a further filter for companies to not report information. For example, it represents a step backwards from ID-177, which says that most S1 metrics must be reported if S1 Own Workforce is material.  It is essential to maintain the principle of fair presentation in the reporting standards.  It is positive that the revision of the AR 16 list of topics has maintained all of the sub-subtopics for S1 + S2. These are based on the list of social topics in the CSRD and should all be maintained.  The emphasis on aggregation (as opposed to disaggregation) is concerning, as disaggregated information (both site-specific and country-specific) is key to understanding the distribution of IROs."]
["Survey","Global Unions' Committee on Workers' Capital","Trade union","Canada","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material.  Reporting on financial effects is crucial to achieving the objective of putting sustainability reporting on the same level as financial reporting and integrating both. The European Union has recognised the value of a double materiality approach to corporate reporting which requires disclosure of both material environmental and social impacts, risks and opportunities as well as financially material data, It is important to keep the requirement on businesses to analyse and understand the financial effects of their business model. This will ensure investors have access to credible data as well as providing the underpinning for future business planning."]
["Survey","Global Unions' Committee on Workers' Capital","Trade union","Canada","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Agree that the following mandatory datapoint should be added: ESRS 2 General disclosures – BP 1 the undertaking shall state that the general requirements of ESRS 1 have been applied for the preparation of its sustainability statement"]
["Survey","Global Unions' Committee on Workers' Capital","Trade union","Canada","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","The new, simplified framework makes it easier for companies to report on these SFDR-related matters in a way that corresponds to how their policies are set. For users, this consolidation makes it easier to locate the relevant information. However, the SFDR datapoints are very helpful and should only selectively be amended."]
["Survey","Global Unions' Committee on Workers' Capital","Trade union","Canada","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The definition of own workforce should be expanded to include franchise workers. The term \"non-employees\" should be supplemented with the phrase \"non-employee workers\" or \"non-employee workers in own workforce\"."]
["Survey","Chartered Accountants Ireland","Auditor","Ireland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Chartered Accountants Ireland","Auditor","Ireland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We note that this consultation has been conducted over a 60 day period over the summer months of August and September. We have concerns as to whether this short period will allow for sufficient due-process to be carried out. Despite the simplifications achieved, we would question whether the 60 day period is adequate for sufficient and comprehensive stakeholder engagement."]
["Survey","Observatorio RSC","NGO","Spain","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We do not agree that the proposed 57% reduction in mandatory datapoints achieves an acceptable balance. While eliminating redundancies is useful, many deletions affect areas that are central to transparency and accountability. The trimming of narrative PAT disclosures and of the DMA process weakens traceability and comparability; in NEIS 2, key governance datapoints (board independence, sustainability expertise, risk methodologies) are no longer guaranteed; in NEIS G1, critical issues such as whistleblowing, supplier due diligence, anti-corruption training and lobbying transparency are downgraded. Coupled with broad burden reliefs, this reduction risks entrenching data gaps and encouraging minimal compliance. A leaner standard is desirable, but it must preserve core datapoints on materiality, governance and business conduct to ensure the credibility of the ESRS and alignment with EU Green Deal objectives."]
["Survey","Observatorio RSC","NGO","Spain","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Observatorio RSC","NGO","Spain","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Observatorio RSC","NGO","Spain","35.G1-5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","The revised G1-5 makes only minor adjustments and continues to require disclosure of political contributions and lobbying activities. However, the removal of datapoints on registration in transparency registers and the lack of disaggregation of lobbying expenditures significantly weaken the disclosure. Without explicit information on whether undertakings are enrolled in official registers (such as the EU Transparency Register) and without a breakdown of membership fees or indirect lobbying through industry associations, stakeholders are left with partial and potentially misleading information.  Lobbying and political influence are highly material areas, directly linked to policy capture and misalignment with sustainability objectives. High-level narrative reporting on \"topics and positions\" is insufficient. To ensure accountability, G1-5 should include mandatory disclosure of registration status, disaggregated lobbying expenditures, and alignment of association memberships with stated sustainability commitments. Otherwise, the risk of green- or social-washing through lobbying remains significant.","G1","Disclosure Requirement G1-5 - Metrics related to political influence and lobbying activities",""]
["Survey","UGT-ESPAÑA","Trade union","Spain","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The Exposure Draft removes duplications between the cross-cutting and topical standards. The preservation of the 4-part architecture in the social standards is important to respect the distinctiveness of different affected stakeholder groups.    However, we have two critical concerns. First, the original DR in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. We welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened. Second, we strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics should not imply that entity-specific metrics for S topics should not be disclosed."]
["Survey","UGT-ESPAÑA","Trade union","Spain","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","UGT-ESPAÑA","Trade union","Spain","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","It is essential that financial institutions disclose absolute targets to assess how their strategies align with the economy-wide transition to net zero. Absolute targets are relevant for users of sustainability statements and for understanding the real-world climate impact of financed activities. While intensity measures provide insights into efficiency, they can mask rising absolute emissions in growing portfolios or sectors.   Granting an exemption would also undermine fairness in a sector-agnostic standard. Other industries could equally argue for exceptions based on their own difficulties, reducing comparability across sectors. Moreover, absolute financed emissions are already recognised in existing standards and regulations: the SBTi financial sector net-zero standard, the UNEP FI/NZBA recommendations, and EU SFDR all require or encourage absolute emissions disclosure. Exempting banks would risk misalignment and reduce the usefulness of reported data for stakeholders, including asset owners who depend on it for their own disclosures."]
["Survey","UGT-ESPAÑA","Trade union","Spain","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We are concerned that the loss of many specific datapoints related to workers in the value chain will mean that disclosures about material impacts, risks and opportunities become more generic and have less information about the specific stakeholder groups because specifications about the level of granularity have been deleted. Many of the points that are being deleted from ESRS S2 had originally been included because they reflected effective practice in relation to improving supply chain labour rights, for example, AR 6 awareness of the impacts on value chain workers from an undertaking's strategy or business model, AR 20 illustrating how the perspectives of value chain workers have informed specific decisions or activities of the undertaking and AR 25 which looks at retaliation and whether workers can use grievance mechanisms confidentially."]
["Survey","Economy for the Common Good (ECOnGOOD)","NGO","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We support simplification, and the proposed amendments largely achieve this. In our view, it would not have been necessary to completely delete the \"may disclose\" elements. Rather, some could have been retained as useful examples of disclosures, particularly to help first-time preparers understand what type of information is likely to be relevant."]
["Survey","Economy for the Common Good (ECOnGOOD)","NGO","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","The exceptions are reasonable and, in our view, do not represent an additional burden."]
["Survey","Economy for the Common Good (ECOnGOOD)","NGO","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Add references to relevant global frameworks, such as SBTN (Measure, Set & Disclose Targets) and TNFD (Sector guidance and guidance on Target Setting)."]
["Survey","Economy for the Common Good (ECOnGOOD)","NGO","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Economy for the Common Good (ECOnGOOD)","NGO","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Alliance for Water Stewardship (AWS)","NGO","United Kingdom","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree"]
["Survey","Alliance for Water Stewardship (AWS)","NGO","United Kingdom","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"- Value chain context should not be lost, upstream value chain is usually most resource intensive as well as most impacting.  - All corrective/mitigation actions should have a time frame limitation.  - Reporting without corrective action is useless, use the ESRS implementation as an opportunity to make a difference and encourage best practice. - More guidance and examples could prove useful."]
["Survey","Harri Timonen Consulting OU","Consultant (including software vendor)","Estonia","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","The short-, medium-, and long-term time periods are essential in other standards (ISSB and GRI) when concerning materiality of the risks, opportunities, impact and dependencies. Precise and correct data is crucial to follow actions, metrics (eg. SASB) and targets. I don't see that lack of data should be the biggest issue, maybe collecting correct and appropriate data. Even for that there are other options e.g. industry, sector and country databases, which e.g. ISSB references. Additionally, comparing it to competitors helps too. And, we are moving so fast towards better data quality that it should be supported to provide accurate data rather than give relief. Again, forward-looking entities should benefit by taking extra miles and be trend-setters in this area."]
["Survey","Harri Timonen Consulting OU","Consultant (including software vendor)","Estonia","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","I have just gained FSA certification and fair presentation is discussed in the study material. ISSB standards are based on relevance and fair presentation which make sense. Then again GRI has similar principles. Hopefully, in the future the reports could be implemented according to same principles which all the standards setters could agree. In the end, they are not that different but rather have different wordings. Providing accurate, relevant and honest data should be main goal and benefit any report reader."]
["Survey","Harri Timonen Consulting OU","Consultant (including software vendor)","Estonia","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","I agree, this content should align with SBTN. Generally, the existing frameworks should be used as much as possible to make use of tested best practices, avoid creating new similar framework, and avoiding extra work and costs moving to other framework."]
["Survey","Harri Timonen Consulting OU","Consultant (including software vendor)","Estonia","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Anker Research Institute","NGO","United States","35.S1-9."," Do you agree with the amendments of this chapter? ","I disagree",null,"S1","Disclosure Requirement S1-9 - Adequate wages",""]
["Survey","Clean Clothes Campaign","NGO","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","It's good that Chapter 3 now describes how prevention, mitigation and remedy factor into materiality, but the guidance could be made simpler. As an example, Para 34 uses highly complex language to illustrate a simple point: entities should assess actual impacts as they occured over the reporting period; any remediation that has occurred ater that does not change the materiality. This should be stated quite concise and clear.  We agree with, and want to emphasize, the clarification that potential impacts requiring significant, ongoing prevention and/or mitigation should be assessed on 'gross' basis (meaning, before management effects). Otherwise it makes it difficult for entities to explain how they mange such issues.  To help make this workable and practical, it would be good to link this section to the \"materiality of information\" filters. That can help entities to distinguish what counts as *significant* prevention/mitigation, from routine compliance and common practice. Describing some criteria and examples (like scale, cost, duration, deviation from baseline) would improve consistency."]
["Survey","Clean Clothes Campaign","NGO","Netherlands","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Interoperability is good, while noting that overall Reliefs should definitely not go beyond those set in IFRS."]
["Survey","Clean Clothes Campaign","NGO","Netherlands","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","The new drafts removed the data point on invoice payment times, which is useful for assessing the protection of SMEs from unfair payment practices.  In contrast, the retained metric—\"number of legal proceedings for late payments\"— is of limited relevance, as such proceedings are rare, particularly in the case of vulnerable suppliers."]
["Survey","Clean Clothes Campaign","NGO","Netherlands","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We are concerned about the combined effect of various reliefs, and about unclarity due to the confusing explanation of the relationship between impacts, risks and opportunities on one hand, and sustainability topics on the other."]
["Survey","Clean Clothes Campaign","NGO","Netherlands","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, being the standards that lack any metrics."]
["Survey","ESG Portfolio Management","User (analyst, data provider, rating agency, etc.)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I disagree","Better metrics are necessary PAIs should be used"]
["Survey","ESG Portfolio Management","User (analyst, data provider, rating agency, etc.)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I disagree","Better metrics are necessary PAIs should be used"]
["Survey","ESG Portfolio Management","User (analyst, data provider, rating agency, etc.)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I disagree","All PAI metrics are needed as they are required under SFDR"]
["Survey","ESG Portfolio Management","User (analyst, data provider, rating agency, etc.)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","I need absolute numbers to compare developments over time, regardless of inflation and other factors."]
["Survey","ESG Portfolio Management","User (analyst, data provider, rating agency, etc.)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","VELUX Group","Preparer (non-financial preparing a sustainability report)","Denmark","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","VELUX Group","Preparer (non-financial preparing a sustainability report)","Denmark","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","VELUX Group","Preparer (non-financial preparing a sustainability report)","Denmark","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","VELUX Group","Preparer (non-financial preparing a sustainability report)","Denmark","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Reporting and Economic Analysis Committee of the Scientific Council The Accountants  Association of in Poland (SKwP)","Auditor","Poland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","OM: Overall, I raise no objections to Chapter 9. Nevertheless, enterprises will continue to prepare statements, declarations or reports covering various environmental and social aspects for different institutions, while the ESRS standard allows their presentation within the sustainability report (para. 8.2, point 107). This, however, results in environmental and social reporting still being duplicated in many respects. My main recommendation is therefore the creation of a single, standardised report from which the respective institutions could obtain the necessary information. At present, the situation is reversed – enterprises are obliged to provide the same data repeatedly to different bodies."]
["Survey","Reporting and Economic Analysis Committee of the Scientific Council The Accountants  Association of in Poland (SKwP)","Auditor","Poland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","KKP: Disclosure requirements related to sustainability should be applied with the aim of communicating information to users rather than merely fulfilling a compliance exercise. Service providers, however, tend to focus predominantly on compliance (particularly in the context of the DMA process). Consequently, the language used is often highly technical and difficult for an \"ordinary\" user to understand. KKP: It should be noted that in 2012 EFRAG published a discussion paper \"Towards a Disclosure Framework for the Notes\", which emphasized that \"Disclosures should be clear, balanced, concise and written in plain language.\" The key observation was that \"Disclosures are often written or presented in a style that makes them difficult to read and understand. Therefore, they fail to provide an adequate explanation of the subject matter\" (EFRAG, 2012, p. 17).  KKP: Future obligation for XBRL tagging – This should be implemented only after market practices for non-financial reporting have been established."]
["Survey","The Future of Sustainable Data Alliance (FoSDA)","User (analyst, data provider, rating agency, etc.)","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","With respect to materiality, it is positive that the ESRS are now put forward as a fair presentation framework based on relevance and faithful representation, rather than being perceived as more compliance-driven. The changes should help companies to report sustainability information in a way that is most tailored to their business model and that will be decision-useful to their own operations as well as to capital providers and other stakeholders. We also welcome the move to make the ISSB sectoral standards permanently available as a tool for meeting ESRS requirements. While commending EFRAG on successfully balancing a wide set of aims and ambitions,  there are some aspects of the draft standards that we question.  Companies' materiality assessment disclosures remain mandatory, but this position is weakened by making it voluntary for them to explain why a topic is or is not material. It is quite possible that different companies in the same sector may have different views on the materiality of data points leading to the creation of data gaps or the use of a mixed set of direct data and estimates. To safeguard consistency and sector-level comparability, further guidance is needed, including practical examples and clear prescriptions to help build capacity among companies."]
["Survey","The Future of Sustainable Data Alliance (FoSDA)","User (analyst, data provider, rating agency, etc.)","United Kingdom","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","In the recently released exposure drafts, EFRAG suggests the elimination of most PAT data points and the removal of metrics related to biodiversity and ecosystems that would damage the alignment between the ESRS and TNFD core disclosure metrics, especially for those metrics related to land-use change, freshwater-use change and/or sea-use change. We also note that the removal of the requirement to provide location specific information will significantly reduce the usefulness of the remaining biodiversity disclosures and will reduce interoperability with the TNFD framework – one which the ISSB may adopt in time. We recommend the reinstatement of data points that will allow location specific analysis and a further review of the alignment with TNFD's key metrics."]
["Survey","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Please see comments on spreadsheet attached, containing details on the different disclosure requirements"]
["Survey","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","We would encourage to ensure compatibility with other widely used frameworks, such as GRI.  Please see more comments in the attached spreadsheet"]
["Survey","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","We recommend adding a voluntary option to report the adjusted gender pay gap."]
["Survey","FuelsEurope","Business association (other than association of financial institution)","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","Relief clauses play a fundamental role, especially in the first reporting years, as they allow companies the necessary time to collect and consolidate data. It would be ineffective and disproportionate to require data solely for the sake of comparability when the underlying information is not yet sufficiently mature to ensure reliability – thereby defeating the real objective of comparability itself.  Below, further explanation supporting why the use of reliefs is extremely important for preparers, in particular: -\tRelief for metrics in the value chain: Collecting quantitative data from all actors within the value chain can be particularly burdensome. Therefore, the possibility to use estimates focused on the most relevant parts of the value chain is crucial. -\tRelief for acquisitions/disposals: Companies need sufficient time after an acquisition to set up systems for collecting sustainability data and to organize the information flow for reporting. It is estimated that at least six months are required for these activities; hence, the relief provides an adequate time frame to initiate high-quality data collection. -\tRelief for data quality on metrics: Please refer to the comment provided in response to question 18. It should be clarified that reliefs do not contradict fair presentation, allowing companies to protect sensitive information without being pressured by auditors to report under this clause."]
["Survey","FuelsEurope","Business association (other than association of financial institution)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","•\tWe strongly disagree with the introduction of new mandatory datapoints, as this would add additional burden and thus contradict the stated objective of the ESRS simplification. Organizations are already facing significant challenges in collecting and reporting the extensive information required under ESRS. Adding further datapoints will increase the complexity of the process, which is still in the early stages of building robust reporting systems. This challenge is particularly acute in the downstream value chain, where companies have very limited visibility and control over how products are used after leaving their facilities. Obtaining reliable data from customers, distributors, or end-users is in practice extremely complex, and in many cases simply not feasible. In particular, we strongly object to the inclusion of the datapoint of secondary microplastic: currently, no risk-based framework exists that enables undertakings to evaluate how their own activities —or those of actors in their value chain— may contribute to potential downstream harms from secondary microplastics. This undermines the reliability and auditability of such disclosures.   •\tWe recommend removing the proposed disclosure requirement on secondary microplastics in paragraph 16(d) of the amended ESRS E2, alongside removal of definitions related to synthetic polymer microparticles and secondary microplastics in Annex II. They are inconsistent with both the legal limits of Set 1 and the EC's mandate to streamline and clarify ESRS reporting obligations.  •\tFurthermore, it is important to note that these four DRs are not the only addition in the revised version. Concept like \"fair presentation\", \"Gross Vs Net\" or the need to amend the base year for targets in case of major acquisition are all new concept, which will introduce further complexity for preparers."]
["Survey","FuelsEurope","Business association (other than association of financial institution)","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","Yes, we should always consider more and more the importance of feasibility and coherence in reporting according to different legislations."]
["Survey","FuelsEurope","Business association (other than association of financial institution)","Belgium","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","FuelsEurope","Business association (other than association of financial institution)","Belgium","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","•\tIndirect Business relationships: should only include those directly linked to the undertaking's business operations, products or services. •\tHuman rights incident: should only include confirmed incidents, and not those that are still under investigation at the end of the reporting period. •\tRisks: should be qualified to material risks. \tValue chain: limit the scope of the impact materiality assessment to entities in the value chain for which the undertaking has a direct contractual relationship. Large multinational organizations are operating within highly complex and expansive value chains. Tracking and assessing impacts beyond direct contractual relationships presents significant practical and operational challenges, particularly in the absence of consistent data availability and supplier transparency."]
["Survey","FuelsEurope","Business association (other than association of financial institution)","Belgium","35.E1-6."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","•\tWe are in favour of removing the Net Zero definition, but we believe it would be possible to report GHG emission reduction targets on a net basis, and not only on a gross basis.","E1","Disclosure Requirement E1-6 - Targets related to climate change",""]
["Survey","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The proposed simplifications create meaningful flexibility for reporting and are consistent with the requirements of IFRS S1 and S2, which we welcome. Particularly noteworthy is the introduction of the principle of \"undue cost or effort\", as it supports pragmatic implementation. In addition to the option of partial coverage, a purely qualitative disclosure should also be permitted, provided that it is sufficiently transparent and meaningful.  At the same time, efforts should be made to improve data quality. This is particularly relevant for financial institutions that rely on improved customer data for both regulatory requirements and strategic management.  In order to ensure transparency and promote continuous further development, the application of the simplifications could therefore be accompanied by regular, though not necessarily annual, reassessment that are proportionate in terms of cost and benefit."]
["Survey","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We generally consider the reduction of mandatory datapoints to be a step in the right direction. However, the announced reduction in the number of datapoints wouldn't lead to a siginificant reduction of reporting efforts, which is more likely to be moderate to minimal. This is partly because many removed datapoints were already classified as non-material in the first report. On the other hand, the expected simplification is offset by the effort required for the implementation of modificationsand by largely unchanged expectations regarding auditing processes and documentation. However, we appreciate the efforts to strike an acceptable balance between workload and information value.  Due to comprehensive regulatory requirements, such as the EBA Guidelines on ESG Risk Management, as well as data requirements for strategic management (portfolio, risk, etc.), financial institutions depend on prompt and continuous improvement of customer data. These needs should be taken into account when removing data points. We are interested in a permanently established core set of decision-useful data that does not need to be adjusted regularly. Continuity is the key to a robust reporting framework that aims to provide meaningful information over time."]
["Survey","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","The current wording is closely oriented on the area targets according to Global Biodiversity Framework (GBF). However, there is empirical evidence to suggest that area alone does not automatically lead to a positive contribution for biological diversity and functioning ecosystems. It would therefore be sensible to also take into account the targeted stabilisation or improvement of the 'state of nature' i.e. the status of species and ecosystem functions. The focus should not be placed exclusively on rare or endangered species, as the decline in flora and fauna affects the entire range (keyword: population protection). We propose the following amendment to AR26 (amendments are marked in CAPITAL LETTERS): Measurable targets related to biodiversity and ecosystems may, for example, refer to the following aspects: •\tSize and location of all habitat areas IN WHICH THE STATE OF NATURE IS PROTECTED OR HAS BEEN restored, whether directly or indirectly controlled by the undertaking, and whether the success of the restoration measure was or is approved by independent external professionals; •\tRecreated surfaces ((environments in which management initiatives are implemented so as to create a DIVERSE habitat WITH BIODIVERSITY THAT IS SPECIFIC OF THE LOCATION where it did not exist initially); •\tNumber or percentage of projects / sites whose ecological integrity was improved (e.g., installation of fish passes, wildlife corridors). The addition of \"specific to the location\" is important since otherwise any change, including those that would not serve to protect nature (e.g. the planting of non-native species or faunal distortions), could be considered renaturation. Given the dynamic development in this area, it would seem sensible to promote the application of a standard recognised in this sector, instead of making the requirements mandatory."]
["Survey","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The amendment is generally reasonable. But the \"undue cost or effort\" principle is too broad, as indicated in the response to question 19."]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","22.E3.","Comments on deleted datapoints in ESRS E3","I partially agree and partially disagree","The simplification proposal is depriving users of the sustainability report from information. However, given the EU mandate the proposal has achieved a reasonable balance."]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","The simplification proposal is depriving users of the sustainability report from information. However, given the EU mandate the proposal has achieved a reasonable balance."]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","Processing information about wages, considering notions such as living wages, is a significant concern for society.   This modification is not justified on the grounds of administrative simplification, as the costs of processing this information is minimal: this information is present in information systems and calculations are trivial. Instead, this modification seems to be proposed on the grounds of avoiding information that may affect corporate reputation."]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","CSEAR; Universidad de Burgos","Academia","Spain","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Des Enjeux et des Hommes","Consultant (including software vendor)","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","-\tIf the top-down approach is used : o\tdoes it mean that the rating is not required at the IRO level and that the identification of IRO is enough ? o\tdoes it mean that a topic/ sub-topic could be excluded without having identified the IROs ? How should it be materialized ? -\tOn one side Combining S1 and S2 may be confusing as these topics are substantially different and the materiality may significantly differ from one topic to another (Reality may be hidden). On the contrary, 3 subtopics for Affected Communities is somehow hard to evaluate and could be aggregated.  -\tThe link between the topics/ subtopics and the data points to be reported should be done at the data point level to ease the process. -\tCould you add an example to illustrate significant variation of IROs between sites and the incidences on aggregation or disaggregation ?"]
["Survey","Des Enjeux et des Hommes","Consultant (including software vendor)","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","The reliefs are deemed to be appropriate."]
["Survey","Ecoacsa","Consultant (including software vendor)","Spain","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","E4","We do not support the removal of the ESRS E4 biodiversity and ecosystems metrics metric specifications from the mandatory requirements. This is problematic because standardization is more limited at present than with other metrics. Specifying metrics (now in Non-Mandatory Illustrative Guidance (NMIG) 18-20) within the Standard would give companies the information they need to select and report practical, credible and comparable metrics and would support alignment with the TNFD disclosure metrics. If this does not occur, at the very least, it is important that (i) the NMIG stays attached to the Standard in some form and (i) a process is in place for ensuring updates are made on a timely basis, particularly for guidance on topics where data/tools for reporting are evolving rapidly."]
["Survey","Ecoacsa","Consultant (including software vendor)","Spain","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We support the simplified standards aligning with core elements of TNFD and encourage EFRAG to continue striving to maintain alignment with other international standards and frameworks, including ISSB and GRI. Improving the interoperability between the requirements in ESRS and the ISSB Standards, to enable companies to use the ISSB Standards as a starting point and 'top up' with specific impact disclosures to achieve compliance with the CSRD/ESRS, is important."]
["Survey","Ecoacsa","Consultant (including software vendor)","Spain","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Ecoacsa","Consultant (including software vendor)","Spain","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Ecoacsa","Consultant (including software vendor)","Spain","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Clean Air Fund","NGO","United Kingdom","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","CAF acknowledges that streamlining the standards and focusing on quantitative information can be positive if it allows companies to dedicate resources to producing better quality and more relevant disclosures. A leaner set of datapoints can also reduce duplication and administrative burden. However, the scale of reduction in the current draft raises significant concerns. Cutting more than half of mandatory datapoints risks undermining transparency on core environmental issues, particularly pollution. Many of the datapoints removed affect the core integrity of the standards. By shifting substantial content into non-mandatory guidance, the draft risks reducing the ability to ensure consistent, comparable and reliable disclosures across companies and sectors. This risks turning simplification into deregulation: companies may report less, with wide variations in scope and quality, making it harder to assess their real environmental and health impacts. CAF strongly believes that simplification should not become deregulation. The risk of the current draft is that it produces fewer datapoints of lower quality, not fewer datapoints of higher quality. The ESRS must ensure that where pollution is material, the information reported is consistent, comparable, and decision-useful. This requires disclosures to link to concrete action: simply listing policies or resources is insufficient unless companies show how these translate into real mitigation outcomes."]
["Survey","IMA-Europe ","Business association (other than association of financial institution)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The reorganization of content—clearly distinguishing mandatory requirements from non-mandatory guidance—is cosmetic. The removal of \"may disclose\" datapoints eliminates ambiguity and strengthens the consistency of interpretation across reporting entities.  The relocation of all \"shall disclose\" datapoints into the main body of the standards, along with the placement of mandatory Application Requirements directly beneath the relevant Disclosure Requirements (DRs), improves the logical flow and usability of the standards. This structure helps preparers better understand what is required and how to report it, reducing confusion and supporting more consistent implementation.  The revised language is also more concise and coherent, which contributes to improved accessibility, particularly for first-time reporters and cross-functional teams involved in contributing to the sustainability reporting."]
["Survey","IMA-Europe ","Business association (other than association of financial institution)","Belgium","22.G1","Comments on deleted datapoints in ESRS G1","I disagree","For G1 Business Conduct confirmed incidents - This may lead to issues concerning the protection and disclosure of sensitive data (confidentiality)."]
["Survey","IMA-Europe ","Business association (other than association of financial institution)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","Explicitly requiring the adoption of fair presentation in the preparation of ESRS sustainability statements would strengthen the application of the materiality filter and enhance the relevance of reported information. Fair presentation ensures that disclosures are complete, balanced, and free from bias. By embedding this principle, undertakings are guided to report only on sustainability matters that are genuinely material, based on their impacts, risks, and opportunities. This approach discourages excessive or superficial reporting and supports a more disciplined and transparent materiality assessment. Moreover, fair presentation contributes to the clarity and usability of sustainability information. It helps stakeholders—particularly investors and regulators—navigate disclosures more effectively, focusing on what is decision-useful rather than being overwhelmed by immaterial data. In this context, fair presentation acts as a safeguard against both under-reporting and over-reporting, thereby improving the overall quality and comparability of sustainability statements across entities."]
["Survey","ESBG WSBI","Association of financial institutions","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Changes in PAT were welcoming, especially the removal of plans and timelines for PAT implementation. We also welcome the simplification of the MDRs (now GDRs), which provides more flexibility. At the same time, it is important to maintain PATs for material IROs (if adopted) as a reporting point in ESRS 2.  Within GDR-A (new paragraph 38), more information should be given on the materiality threshold of what is considered as \"significant resources,\" as this is still subjective and could be an issue during audit. The materiality/threshold could be defined by the undertaking, disclosed in the general disclosures, in order to support consistency and auditability.   We also recognise that GDR-A introduces helpful flexibility by allowing voluntary disclosure of sustainability-related CapEx and OpEx. However, its applicability to financial institutions is limited. In this sector, sustainability-related resources are typically channelled through financial products—such as loans, investments, or insurance—rather than through own operations. As a result, these figures may not be operationally relevant or material."]
["Survey","ESBG WSBI","Association of financial institutions","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Welcoming changes. Overall, we believe the proposed amendments achieve the desired level of clarity and accessibility, and the overall structure of the standards contributes to this.  Remaining ambiguity in \"may\" language: Although most \"may disclose\" datapoints were removed, some still remain (e.g., ESRS 1 p.114–115), which could cause confusion and should be reconsidered.  Terminology consistency: Terms like \"material topics\" vs. \"material IROs\" and \"adverse\" vs. \"negative\" impacts are used interchangeably, which may lead to interpretation issues and audit challenges.  Application Requirements (ARs): Wording such as \"shall consider\" in ARs creates ambiguity. It's unclear how \"consideration\" can be measured or audited, potentially leading to burdensome discussions with auditors.  Need for datapoint mapping: A correlation table between old and new datapoints would help preparers transition and reduce implementation costs."]
["Survey","ESBG WSBI","Association of financial institutions","Belgium","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","FOR ALL: We are positive to the reduction of \"shall disclose\" requirements, specifically the narrative PAT disclosures. We do not believe this burden reduction is in conflict with fulfilling the objectives of the EU Green Deal.  Not all reductions will lead to less reporting effort: While the number of datapoints has decreased,  (a)\tthe simplifications may have taken place to topics that are not material to the undertakings (b)\tnew concepts and methodologies may increase complexity.  Ambiguity in remaining provisions: Some paragraphs (e.g., ESRS 1 p27, AR 20 to p49) still use vague language like \"useful information\" or \"possible aspect to cover,\" which may create uncertainty."]
["Survey","ESBG WSBI","Association of financial institutions","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","ESBG WSBI","Association of financial institutions","Belgium","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","ESBG WSBI","Association of financial institutions","Belgium","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Rainforest Action Network","NGO","United States","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","It is essential that financial institutions disclose absolute targets so that there is clarity about how their strategies align, or not, with the goals of the Paris Agreement.  Intensity metrics can mask increase in absolute emissions, and are therefore not suitable for this type of disclosures."]
["Survey","Rainforest Action Network","NGO","United States","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Fidelity International ","Asset manager/Investor","Luxembourg","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We support these changes. We are of the view this would improve the readability of disclosures. We also believe further changes could be made to improve readability of disclosures which can be technical and overly complex - an acknowledgement that reports can be prepared 'in plain English' and be focused on supporting consumer readability may help improve this."]
["Survey","Fidelity International ","Asset manager/Investor","Luxembourg","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Fidelity International ","Asset manager/Investor","Luxembourg","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","We think this proposed changed should support investors reviewing corporate disclosures in the long term."]
["Survey","Japanese Bankers Association","Association of financial institutions","Japan","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","- We agree with the improvements in readability, conciseness, and connectivity. - The amendments are beneficial in clarifying that only material topics, not the full topical standards, need to be reported, thereby enhancing both flexibility and efficiency in sustainability reporting. Additionally, the introduction of new concepts such as \"only once\" and \"undue cost and effort\" helps reduce the practical burden in identifying IROs, determining the scope of the value chain, and reporting metrics, thereby promoting connectivity with corporate reporting as a whole. - Moreover, these amendments contribute to enhancing interoperability with other international reporting standards such as the ISSB and SSBJ, supporting both practical applicability and global alignment of the ESRS framework."]
["Survey","Japanese Bankers Association","Association of financial institutions","Japan","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","- While the amendments are generally consistent with ISSB Standards, we are concerned that certain disclosure requirements exceed those of ISSB Standards and may impose additional burdens on preparers. Specifically, the quantitative disclosures in paragraphs 41(a) and 41(b) exceed requirements under ISSB Standards, and could be particularly challenging for entities reporting under multiple frameworks. - To enhance alignment with international standards and ensure practical feasibility, such requirements should be reconsidered for optional disclosure or removal."]
["Survey","Japanese Bankers Association","Association of financial institutions","Japan","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","- We agree that financial institutions should be exempted from disclosing absolute GHG emission reduction targets when they have only set intensity-based targets. For example, in the power sector, emission intensity is often used as a more appropriate metric due to the necessity to meet growing electricity demand while transitioning to cleaner energy sources. - Similarly, for financial institutions whose emissions largely depend on investees and borrowers, setting absolute targets can be impractical. Intensity-based targets are often more reasonable and reflective of their operational realities. Therefore, the proposed exemption is appropriate and supports flexibility and feasibility in implementation."]
["Survey","German Environment Agency","National supervisory authority & regulator","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","German Environment Agency","National supervisory authority & regulator","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We note that certain proposed amendments might impede interoperability between the ESRS and IFRS S1 and S2. However, given that the IFRS standards have not been tested in practice and have simplification potential on their own, we recommend that EFRAG prioritizes simplifications and improvements derived from reporting experience over IFRS interoperability."]
["Survey","German Environment Agency","National supervisory authority & regulator","Germany","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","We submit our detailed comments in part 3 of the questionnaire respone."]
["Survey","German Environment Agency","National supervisory authority & regulator","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Please see our detailed feedback on ESRS 1 and 2, ESRS E1, E2, E3, E4 and E5 in the excel sheet submitted in part 3 of the questionnaire and in our opinion paper."]
["Survey","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The overall simplification of Chapter 3 is welcome. We find the new chapter 3.5. with practical considerations particularly helpful, as it has a potential to relieve large portion of the burden undertakings faced performing their materiality assessments. However, we have several comments to changes we don't agree with: (1) The materiality of information principle should not be applicable to ESRS 2, as it provides key information for users on ESG management as required by CSRD and may result in omitting fundamental information required in sustainability statements, such as on the DMA process and its results, or the governance over sustainability matters, and details on the undertaking's business model and strategy. The principle of materiality of information is highly judgmental and should be applied with caution. (2) Undertakings should not be allowed to include non-material information in sustainability statements, as this will obscure material information. Companies have many other means to communicate to their stakeholders non-material sustainability related information and there is no need to include these information in official, regulated annual reports. (3) Summarizing the list of topics in current Appendix A to only two-level structure is not very helpful, it was more useful as a three-level structure. Maintaining a three-level structure would not add any burden, as the list is illustrative only. We also propose to add for clarity some changes in the list: (a) In \"Climate change\": add \"Loss and damage\" (b) In \"Circular economy and resource use\": add \"Product and service design related to circular economy principles\" (c) In \"Climate change\" replace \"Energy\" with \"Energy, including use of fuels and energy efficiency\""]
["Survey","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland","22.E3.","Comments on deleted datapoints in ESRS E3","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Reduction of the number of mandatory and voluntary data points in the ESRS 2 IRO 1 for E2-E5 standards could cause problems with the proper conduct of double materiality assessment and impair comparability. The existing provisions regarding ESRS 2 IRO 1, found in appendices A, should be reinstated as they provide a reference point for conducting double materiality assessment for environmental issues."]
["Survey","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","TitanX Engine Cooling","Preparer (non-financial preparing a sustainability report)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","TitanX Engine Cooling","Preparer (non-financial preparing a sustainability report)","Sweden","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","TitanX Engine Cooling","Preparer (non-financial preparing a sustainability report)","Sweden","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","TitanX Engine Cooling","Preparer (non-financial preparing a sustainability report)","Sweden","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","TitanX Engine Cooling","Preparer (non-financial preparing a sustainability report)","Sweden","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Dutch Federation of Pension Funds","Association of financial institutions","Netherlands","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We do not support the removal of the requirement to disclose whether a Policy, Action, or Target (PAT) or timelines have been removed for material topics. Transparency is essential, particularly for material negative impacts and risks. Therefore, choosing to remove PATs should require an explanation. Without an explanation, companies may simply state \"no PAT\" without clarifying existing gaps or intended actions, weakening accountability and comparability for investors.  We also have concerns about the reformulation of certain mandatory datapoints into Application Requirements (ARs). The legal status of ARs may be unclear to preparers, potentially leading to inconsistent interpretation and reduced enforceability. Clear communication that ARs represent mandatory methodological guidance is essential to maintain consistency and reliability in reporting. Finally, we support the restructuring of the reporting architecture, which promotes conciseness and reduces duplication. It is important that companies focus on reporting what is most material to their operations, while maintaining clarity and completeness for users of sustainability information."]
["Survey","Dutch Federation of Pension Funds","Association of financial institutions","Netherlands","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We consider the proposed datapoints highly relevant for investors, as they clarify key elements essential to assessing a company's sustainability performance and risk exposure. Their inclusion can enhance transparency, comparability, and the overall decision-usefulness of reported information."]
["Survey","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Why should they be exempted?"]
["Survey","Impronta Etica","NGO","Italy","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Impronta Etica acknowledges and appreciates EFRAG's efforts to clarify the most critical aspects of the previous ESRS Standard, but expresses partial disagreement with the new guidelines regarding their clarity and contribution to enhancing the comparability of reporting. The text of the Standard concerning remedy, mitigation, and prevention actions within the double materiality process remains unclear and linguistically complex. This complexity may generate significant difficulties for companies, opening the way to possible divergences in the interpretation of the text. Furthermore, the lack of practical examples exacerbates these difficulties, making it challenging for companies to fully understand how to approach this section of the double materiality assessment process, and ultimately failing to clearly demonstrate the intended simplification. The need to include practical examples and guidance tools to illustrate how to concretely implement the changes introduced is therefore reiterated. In addition, to further streamline the double materiality process, it is suggested to extend the changes introduced also to the risk assessment system. Finally, it is recommended to provide a deeper definition of opportunities, in parallel with what has already been done for positive impacts, in order to harmonize and comprehensively clarify practices as a whole."]
["Survey","University of Padova","Academia","Italy","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","The proposed amendments do not achieve acceptable balance between simplification and robustness . While point (a) in the definition of double materiality is clear, point (b) is imprecise and tautological: \"Information is MATERIAL when: (…) it is necessary (…) to understand (…) MATERIAL impacts, risks and opportunities …\" (emphasis added) The inclusion of \"risks and opportunities\"  is inconsistent with the notion of impact materiality, as illustrated in ESRS 1 (e.g., para 3 and 30). Point (b) refers to the \"understanding\" of sustainability reporting users, without considering implications of such understanding. in para 30 impact materiality refers to \"the identification of information that relates to the undertaking's material actual or potential, positive or negative impacts on people or the environment (…)  direct contractual relationships.\" any framing of impact materiality based on decision-making is insufficient, since many of the stakeholders are not in a position to make any decision (e.g., nature or future generations). if the \"understanding\" and the \"decision-making\" framings of impact materiality are unsuitable, a possible framing for point (b) could be based on the notion of stewardship and due diligence. Suggested alternative wording: \"(b) it is necessary for the corporation to show to a broad range of stakeholders that it identifies and addresses actual or potential, positive or negative impacts on people or the environment\" The focus on he \"materiality of information\" as a general filter (point 2) can help organisations performing DMA, however, the assessment of materiality of information shall not be used as a reason to omit information on a topic that was identified as material.  The possibility allowed by point 6 breaks the traceability between impacts, risks, opportunities, and corresponding metrics, complicating insurability and cross-sectional comparability. Allowing the disclosure of information on non-material topics (para 108) may introduce noise and allow cherry-picking practices biasing \"fair presentation\"."]
["Survey","University of Padova","Academia","Italy","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","It is reasonable to include guidelines and examples on how to disclose datapoints in \"Non-Mandatory Illustrative Guidance\" (NMIG). However, the simplification proposal is depriving users of the sustainability report from crucial information to assess the due diligence of the company. For example, the policies to identify and manage actual or potential, positive or negative impacts on people or the environment, are crucial to assess due diligence. Therefore, it is paramount to perform an in-depth assessment to determine whether all disclosures currently presented in the NMIG should be made mandatory in the delegated act.  While the NMIG may reduce implementation questions, encourage proportional innovation, and ease the burden on PAT narratives when rigid prescriptions fail, it could also reduce comparability. Without a minimum common ground, methodological heterogeneity hinders cross-sectional and time-series analyses. In this regard, the NMIG is useful if it complements—not replaces—a clear regulatory baseline that preserves consistency, traceability, and insurability."]
["Survey","University of Padova","Academia","Italy","22.E2.","Comments on deleted datapoints in ESRS E2","I disagree","The simplification proposal is depriving users of the sustainability report from information."]
["Survey","University of Padova","Academia","Italy","22.G1","Comments on deleted datapoints in ESRS G1","I disagree","The simplification proposal is depriving users of the sustainability report from information."]
["Survey","University of Padova","Academia","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","Thresholds are reasonable"]
["Survey","University of Padova","Academia","Italy","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","University of Padova","Academia","Italy","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We had a first touchpoint with our auditors on the top down approach to the DMA. It remains unclear what is the evidence needed to be able to top-down de-select some topics and select others as material in case there is disagreement between preparer and auditor on the 'common sense' applied to select and de-select."]
["Survey","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Vereniging Milieudefensie","NGO","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material.  Resigning on this ambition is at odds with the objective of putting sustainability reporting on the same level as financial reporting, the integration of both, and ultimately overcoming the tragedy of horizons.  We find Option 1 unnecessarily extensive, and lacking time limitation, but broadly acceptable. We disagree with the assertion made in the question that it \"[d]ifferent from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources \". In this regard, the new proposed ESRS include the undue cost and effort relief which seems to account for such a situation.  With respect to Option 2, we don't find it justifiable to go beyond the IFRS relief. One of the most strongly voiced arguments from stakeholders who called for simplification of ESRS was that, as a matter of principle, ESRS must be aligned with the IFRS except where CSRD or other EU legislation require otherwise. Abandonment of this principle seriously undermines prospects of building a global baseline which both the EU and the ISSB support, and which is an important part of building a level playing field for the EU companies."]
["Survey","Vereniging Milieudefensie","NGO","Netherlands","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","The global carbon budget is defined in absolute terms. For this reason, it remains essential that also financial institutions disclose absolute targets to assess how their strategies align with the economy-wide transition to net zero.  Absolute targets are relevant for users of sustainability statements, for understanding the real-world climate impact of financed activities and for understanding the ambition level of financial insti. While intensity measures provide insights into efficiency, they can mask rising absolute emissions in growing portfolios or sectors. Absolute values, by contrast, give a clear signal of whether institutions are aiming for a fair contribution to the necessary 90–95% global reduction in emissions by 2050, with steep cuts by 2030. Both approaches rely on similar underlying data, and estimation challenges are not unique to the financial sector.  Granting an exemption would also undermine fairness in a sector-agnostic standard. Other industries could equally argue for exceptions based on their own difficulties, reducing comparability across sectors. Moreover, absolute financed emissions are already recognised in existing standards and regulations: the SBTi financial sector net-zero standard, the UNEP FI/NZBA recommendations, and EU SFDR all require or encourage absolute emissions disclosure. Exempting banks would risk misalignment and reduce the usefulness of reported data for stakeholders, including asset owners who depend on it for their own disclosures."]
["Survey","Vereniging Milieudefensie","NGO","Netherlands","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","Vereniging Milieudefensie","NGO","Netherlands","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We particularly welcome the streamlining and alignment of the structure of this standard with the remainder of the standards"]
["Survey","Norwegian Environmental Protection Agency","National supervisory authority & regulator","Norway","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","The Norwegian Environment Agency considers some of the proposed changes appropriate, while others may weaken the environmental integrity of reporting and reduce comparability across companies. The removal of the requirement to report a baseline year is one example that could negatively affect the ability to compare emissions data over time and across entities. We also note several changes—particularly regarding transition plans—that may lower the quality of corporate climate strategies. It is essential that Level 1 regulation(CSRD) includes a clear definition of what constitutes 1.5°C compatibility in a transition plan. Stakeholder feedback highlights the need for more guidance on assessing risks related to locked-in GHG emissions. We recommend considering the inclusion of OECD guidance (e.g., in AR 3 for paragraph 14) to strengthen the qualitative dimension of this assessment. The direct reference to the EU Taxonomy has been proposed for removal from ESRS E1. While we understand the rationale, we emphasize that the taxonomy defines what is considered environmentally sustainable. A credible transition plan should be aligned with these criteria. Removing this link may reduce the quality of corporate transition efforts. E1-4 (new E1-6): Targets related to climate change Paragraphs 36(c) and (d)—now paragraph 26—previously required reporting on base year and baseline value, updating the base year every five years after 2030, and setting emission reduction targets for at least 2030 (and preferably 2050). These requirements now appear to be removed to increase flexibility. However, this change may reduce the ability to assess whether emission reductions are real and comparable across companies. In order to compare data, the base year should continue to be updated every 5th year."]
["Survey","Norwegian Environmental Protection Agency","National supervisory authority & regulator","Norway","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","Clarification of substance-related reporting requirements It has been clarified that requirements related to substances, whether alone or in mixtures, apply specifically to the chemical sector. The reporting obligations have been significantly eased for companies that only use chemicals, with stricter requirements applying to manufacturers and importers. Only manufacturers and importers are required to report on both SVHC (Substances of Very High Concern) and SoC (Substances of Concern), while users are only required to report on SVHC. However, we note that the clarification under AR 6 for paragraph 18 does not align with which entities paragraph 18 is intended to apply to. Reporting requirements for the purchase and sale of articles containing SVHC have been separated out, referencing the 0.1% concentration threshold in REACH Article 33. These requirements apply to manufacturers, importers, and users of such articles. We question whether it is appropriate for this requirement to include companies that are merely users of articles containing SVHC. If the intention is to target companies assembling components into complex products, this should be made more explicit."]
["Survey","Norwegian Environmental Protection Agency","National supervisory authority & regulator","Norway","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","IVL Swedish Environmental Institute","Consultant (including software vendor)","Sweden","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","Yes, I agree that the proposed amendments strike a good balance between burden relief and preserving transparency. The revised paragraphs 46–48, AR 19 and paragraph 65 in ESRS 1 are particularly important improvements.  First, there is now a clear acknowledgement that resources are limited and that effective materiality assessment does not require mapping every possible impact across the entire value chain. Using reasonably available and business-relevant information – such as that already applied in strategy, risk management or due diligence – is sufficient. Starting with the most obvious topics, and then handling potential areas step by step with targeted analysis, is a pragmatic and intelligent process logic. It reduces administrative burden and shifts the focus to substance.  Second, the clarification in AR 19 that quantitative scoring is not required in all cases is crucial. In many situations, a well-reasoned qualitative analysis is enough to conclude on materiality. This avoids unnecessary numerical scoring of issues where materiality is already evident, leading to more efficient and meaningful reporting.  Third, paragraph 65 provides a realistic approach to value chain analysis. Allowing companies to rely on average, regional or sectoral information aligns with how hotspot analyses are already used in practice. Direct data should only be sought when risks are unclear and potentially significant. This creates a useful process structure: start broad with available data, prioritise likely and severe impacts, and go deeper only where necessary."]
["Survey","IVL Swedish Environmental Institute","Consultant (including software vendor)","Sweden","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","IVL Swedish Environmental Institute","Consultant (including software vendor)","Sweden","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I would like to skip this question and provide my feedback in Part 3"]
["Survey","IVL Swedish Environmental Institute","Consultant (including software vendor)","Sweden","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","IVL Swedish Environmental Institute","Consultant (including software vendor)","Sweden","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Samsung Electronics","Preparer (non-financial preparing a sustainability report)","South Korea","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree","The burden reliefs are a positive step and the balance struck is acceptable. The changes reduce costs for preparers while still allowing stakeholders to receive core sustainability information."]
["Survey","Samsung Electronics","Preparer (non-financial preparing a sustainability report)","South Korea","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Qualitative disclosures on anticipated financial effects significantly reduce the burden compared to mandatory quantitative assessments, which are highly resource-intensive and speculative. The relief should remain in place and quantification left voluntary."]
["Survey","Samsung Electronics","Preparer (non-financial preparing a sustainability report)","South Korea","22.E4.","Comments on deleted datapoints in ESRS E4","I agree","The reduction in mandatory datapoints is a major improvement, cutting unnecessary effort while preserving key disclosures. The balance is appropriate, though further reductions could be considered in the future if uptake shows immaterial information is still reported."]
["Survey","Samsung Electronics","Preparer (non-financial preparing a sustainability report)","South Korea","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","The revised methodology for non-EU adequate wages is more practical and reduces reliance on unavailable or unreliable local data sources. This improves feasibility and lowers the effort required for compliance. Removal of reference to the transposition period is also welcome."]
["Survey","Cassa Depositi e Prestiti (CDP)","Asset manager/Investor","Italy","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We welcome the efforts made to simplify chapter 3 of ESRS 1. However, although practical considerations have been introduced, the section dedicated to the DMA still remains complex and burdensome. We find useful the introduction of the concept that \"the undertaking is not required to assess every possible impact, risk and opportunity across all areas of its operations and throughout the upstream and downstream value chains to identify the topics\", and we support the use of the notion of \"reasonable and supportable information that is available without undue cost and effort\". The following specification is also useful: \"the materiality assessment regarding upstream and downstream value chain may be conducted without direct information from counterparts, using average regional or sectoral data or generally available information about the incidence of impacts, risks and opportunities in the given context\". We also support further elements of simplification such as the possibility to not consider all time horizons or each individual assessment variable and the possibility of using qualitative rather than exclusively quantitative considerations in the materiality assessment."]
["Survey","Cassa Depositi e Prestiti (CDP)","Asset manager/Investor","Italy","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","We believe that considering the assessment of \"gross\" impacts makes the outcome of the DMA less meaningful, contrary to the rationale for which this concept was introduced (as expressed in the Basis for Conclusions). In our view, the most appropriate solution is a \"net\" assessment of mitigation measures, since a more flexible approach is required. Moreover, we propose removing the Appendix C Table, as it represents an Application Requirement that is neither clear nor fully consistent with the other specific requirements, and therefore creates confusion. We also deem necessary clarifying the approach to risk assessment, in order to ensure connectivity with the risk disclosures already provided in the financial statements."]
["Survey","Cassa Depositi e Prestiti (CDP)","Asset manager/Investor","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","This provision entails an additional burden for those companies that must report the number of employees and the gender breakdown even for countries that are not necessarily material."]
["Survey","Cassa Depositi e Prestiti (CDP)","Asset manager/Investor","Italy","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We recommend providing specific guidance for financial sector participants, on topics such as the calculation of Scope 3 GHG emissions and the definition of the value chain. Regarding the value chain, given the complexity of data collection and the certainty of its reliability, at this stage it would be appropriate to limit the related reporting requirements.  Regarding E1-7 paragraph 28 (b), this requires a more precise definition of the methodology for calculating energy consumption from nuclear sources."]
["Survey","FRANCE ASSUREURS","Association of financial institutions","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","France Assureurs supports the changes implemented by EFRAG. The elimination of \"may disclose\" datapoints from the standard helps to reduce confusion when preparing the report. The new articulation between DR and AR is also a welcomed proposal that enables undertakings to better navigate the standard and identify the mandatory disclosure requirements. However, \"should/shall consider\" wording should be amended as it is not clear if the related DR are mandatory or optional. Such references should either be replaced by \"shall\" only or \"may\" depending on the case, or otherwise clarified.  Moreover, we note that some AR still include additional information – which could easily be part of the DR - and thus are not always limited to mandatory methodological guidance (e.g. AR 22 for para 51, AR 38 to par 111a, AR 28 for para 29, AR 8 for para 20).    Finally, while we recognise the intent to improve the language of the standards, we call on EFRAG to implement changed terminology with care to avoid misinterpretation or misalignment with prior guidance used by preparers in the first reporting year. Simplification should not create excessive burden to comply with new obligations."]
["Survey","FRANCE ASSUREURS","Association of financial institutions","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We support the reduction in the number of mandatory datapoints and the deletion of all voluntary datapoints in the ESRS. It illustrates EFRAG's efforts and willingness to respond to stakeholders' concerns around reporting complexity, excessive granularity, and operational burden for preparers. However, we would like to draw to EFRAG's attention that the use of several expressions like \"is useful information\" / \"is a possible aspect to cover\" may lead to uncertainty regarding the actual requirements for undertakings and should be clarified. We also consider that efforts in reporting burden reduction could have been further pursued, especially the reduction of \"shall\" DPs, which we would have expected to be the focus of the simplification.  Finally, it is important to note that a 57% reduction in mandatory datapoint will not necessarily translate into a proportional decrease in report length or reporting burden. While we welcome the notable reductions in certain topical standards, significant concerns remain regarding newly introduced concepts and methodologies that may actually increase the reporting effort. Examples include the requirements on fair presentation, the distinction between gross and net impacts, and the mandatory general disclosures for all metrics relating to data types and sources — as well as, for environmental metrics, the disclosure of specific environmental conditions and characteristics of the area where the impact occurs."]
["Survey","FRANCE ASSUREURS","Association of financial institutions","France","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","We regret the deletion of the voluntary datapoint on adjusted gender pay gap, which provided more meaningful information. Indeed, the adjusted basis offers a better understanding of pay equity within organizations, by accounting for relevant contextual factors (employee category, age, country etc.).   While we support efforts to reduce complexity, we believe that optional datapoints with high relevance to key social topics such as pay equity should not be excluded entirely from the reporting architecture."]
["Survey","FRANCE ASSUREURS","Association of financial institutions","France","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","« The simplifications proposed on ESRS S1 still raise significant implementation challenges on the following DR: S1-6; S1-9, S1-12, S1-13, S1-16. Notably, the  current version of the DR related to non-employees (S1-6) and adequate wages (S1-9) are particularly complex to interpret leaving room for varying interpretations and divergent methodologies across companies (e.g. the non-employees number fluctuate depending on the project cycles, for adequate wages the proposed benchmark \"ILO Convention No. 131\" is not a universal legal standard, as it does not define a specific amount or a single methodology…). The requirements linked to these 5 S1 DRs create major operational challenges, in terms of data reliability, resource mobilization, auditability and comparability and should be clarified. »"]
["Survey","A2A","Preparer (non-financial preparing a sustainability report)","Italy","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","A2A believes that the document could be useful as additional, non-mandatory material, but only for further study and clarification of the DPs of the Exposures Drafts. We believe that the non-binding nature of NMIG has to be explicitly communicated and consistently understood by both preparers and auditors. Furthermore, we suggest separating the different types of information contained in the document: for example, if it concerns \"clarifications\" to the DP requests, then these should be included in the Delegated Act. There should be no implicit expectation that the examples provided must be followed or justified if not applied. If, on the other hand, it concerns voluntary DPs, then these should be excluded from the Delegated Act to avoid misunderstandings and confusion among preparers. In the end, an explicit statement confirming that NMIG cannot be used for audit purposes, along with its separation from the legislative text, would reinforce this distinction."]
["Survey","A2A","Preparer (non-financial preparing a sustainability report)","Italy","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","A2A operates in the EU, with more than 95% of its services and plants located in Italy, and therefore only applies ESRS as per CSRD. We selected \"yes\" because we agree with the fact that in Sustainability reporting, there is the need of more interoperability between Standards across Countries."]
["Survey","A2A","Preparer (non-financial preparing a sustainability report)","Italy","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We believe it is essential that all methodological guidelines related to the definition of targets and metrics in the field of biodiversity and ecosystems be maintained within the Disclosure Requirement. Biodiversity is an area characterized by high complexity and variability, so leaving wide discretion in defining metrics could compromise the comparability and reliability of information between companies. Maintaining clear methodological guidelines is therefore essential to support companies in defining consistent and comparable objectives and to ensure the usefulness of information for stakeholders."]
["Survey","A2A","Preparer (non-financial preparing a sustainability report)","Italy","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","A2A","Preparer (non-financial preparing a sustainability report)","Italy","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","A2A","Preparer (non-financial preparing a sustainability report)","Italy","35.E1-1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","We believe it is important that, within the E1-1 Transition Plan disclosure requirement, the trajectory well below 2°C, in addition to the 1.5°C trajectory provided for by the Paris Agreement and the European Climate Law, be explicitly considered. This would allow companies to more accurately represent their transition plans in relation to different decarbonization scenarios that are still consistent with international and European objectives.","E1","Disclosure Requirement E1-1 - Transition plan for climate change mitigation",""]
["Survey","Finnwatch ry","NGO","Finland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","BIOFIN-EU, University of Limerick","Academia","Ireland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","In cases where the disclosure of the impact in future periods is not reported if fully remediated, we raise some concerns related to monitoring of the long-term success of remediation / mitigation activities. We propose introducing a timeframe for disclosure of mitigation actions pending review of success of such actions."]
["Survey","BIOFIN-EU, University of Limerick","Academia","Ireland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","BIOFIN-EU, University of Limerick","Academia","Ireland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We recommend that a clear approach to setting and monitoring biodiversity targets be adopted, (similar to the use of the GHG protocol to guide emissions targets in ESRS E1). We suggest alignment with the UN-SEEA approach, as proposed by the EU-funded Transparent and Align projects."]
["Survey","German Chemical Industry Association - VCI","Business association (other than association of financial institution)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","VCI does not agree with the decision to exclude any relief measure for commercially sensitive information, as referenced in paragraph 70 of the [DRAFT] Basis for Conclusions (i.e. the potential inclusion of a similar provision in the Directive through the Omnibus legislative process). The ongoing legislative process should not prevent EFRAG from directly addressing this issue within the standards—especially after acknowledging that it is a \"concern frequently expressed by preparers\" (paragraph 82 of the Basis for Conclusions). We note that section 7.7 of the current ESRS 1 directly quotes Article 2 of the Trade Secrets Directive in paragraph 106, conditions (a)–(c), which provides clearer alignment with existing EU law compared to previous drafts. However, the current wording limits the scope to information \"corresponding to intellectual property, know-how or the results of innovation,\" thereby excluding other types of commercially sensitive information protected under the Trade Secrets Directive. To ensure consistency and full alignment with the Directive, this qualifying language should be removed. Additionally, the ESRS could offer greater flexibility in this area, following the approach taken in the GRI Standards. GRI 1 allows \"confidentiality constraints\" as a valid reason for omission, provided the reporting undertaking explains the rationale. It should also be considered that the publication of detailed site-level data—including coordinates and types of processes carried out—may be subject to confidentiality, competitive concerns, or trade secret protections. Members also report confusion and uncertainty when disclosing confidential information, particularly in justifying omissions to auditors."]
["Survey","German Chemical Industry Association - VCI","Business association (other than association of financial institution)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","The purpose of the simplification mandate is to reduce the number of data points to reduce the length of the report and to finally strengthen the meaningfulness of the report (and definitely not to increase the number of mandatory data points. Therefore, this is a step in the wrong direction. We therefore recommend to stick to the rule of no additional reporting obligations.  Making E4 Biodiversity transition plans mandatory is not supporting its development but rather hindering development and innovation in this field. The decision to include Biodiversity TP information in reporting shall remain voluntary.  Highlighting the training of procurement team within ESRS G1 is unnecessary detail and focus of one employee group. The addition shall be deleted."]
["Survey","German Chemical Industry Association - VCI","Business association (other than association of financial institution)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","If the disclosure specifications and application requirements for E4-4 (targets) have largely been removed as part of the simplification process, it becomes essential to provide clear and accessible guidance elsewhere. If ESRS Set 1, E4 AR 26 is indeed outdated, it should be urgently revised. This would enable companies to set biodiversity and ecosystem targets that reflect their specific material impacts—where such impacts exist—rather than requiring adherence to a one-size-fits-all approach. The primary objective must remain simplification and reinforcement of the materiality principle, rather than introducing more complex target-setting rules. We have identified two key risks associated with overly prescriptive guidance: -\tBiodiversity metrics remain methodologically underdeveloped. Unlike climate-related metrics, there is no universally accepted methodology. Therefore, flexible target-setting options are essential. -\tDetailed guidance risks undermining the Double Materiality Assessment (DMA) by creating a \"checklist\" mentality. This can pressure companies to report on issues that their own assessments have deemed non-material."]
["Survey","Neuberger Berman","Asset manager/Investor","United States","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","With the upcoming review of the SFDR and the potential changes to Annex I PAIs, it is essential that sustainability disclosures required by the SFDR are based on data that companies already report under the CSRD. In the interim, EFRAG should ensure that the ESRS continues to include all data points linked to the 14 mandatory PAIs. These indicators are vital for the effective implementation of the SFDR and must remain accessible to all users of sustainability reporting."]
["Survey","Copa-Cogeca ","Business association (other than association of financial institution)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","It's positive that the 'may disclose' datapoints have been removed, as it was uncertain what their status and applicability was. We also appreciate language  improvements which have enhanced clarity and readability."]
["Survey","Copa-Cogeca ","Business association (other than association of financial institution)","Belgium","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","See answer to Q18."]
["Survey","Copa-Cogeca ","Business association (other than association of financial institution)","Belgium","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Copa-Cogeca ","Business association (other than association of financial institution)","Belgium","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Eumedion","Association of financial institutions","Netherlands","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Eumedion","Association of financial institutions","Netherlands","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Eumedion","Association of financial institutions","Netherlands","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree"]
["Survey","Danish Institute for Human Rights ","NGO","Denmark","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","DIHR largely supports the substantive content of paras 34 to 36 and appendix C.   However, the drafting is not sufficiently clear and consistent. For example, the reporting year aspect is clear in the Appendix, but not in the main body paras. Further para 34 and 35 can be read to imply 'default net', whereas the table mostly instructs gross for potential impacts.   A 'default net' approach is problematic as. if abused, it may lead to underreporting of negative impacts, undermine transparency objectives of the CSRD and hinder information access by users. Elements of 'the gross approach' are likely to be necessary for users to understand the undertaking's material impacts and how it identifies and manages them and hence critical to para 21 b.   DIHR recommends that a) appendix C is the benchmark for further adjustments to principled descriptions in paras 34-36; b) the gross approach is kept when impacts require significant ongoing actions OR where there is not supportable evidence of the effectiveness of actions; c) that the terms 'gross and net' are avoided; d) that interrelation with severity and likelihood assessment is considered. Assessing likelihood also involves considering preventative and mitigating actions and it is not clear how this interplays with the new gross vs net consideration and finally that e) the interrelation between a net approach and allowing disclosure of non-material information is considered."]
["Survey","Danish Institute for Human Rights ","NGO","Denmark","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","DIHR is not supportive of introducing reliefs in ESRS that go beyond already existing IFRS reliefs. This is to support interoperability, avoid double reporting concerns and increase comparability. In addition it will be important to avoid starting a 'race to the bottom' between ESRS and IFRS as it relates to aligning reliefs across the standards.  The switch from a compliance approach to one of 'fair presentation' marks a big shift and an overall reliance on business judgement. With it comes heightened responsibility on the companies to act in good faith. If not, the framework will lose its ability to underpin the necessary exchanges between preparers and users and ultimately the much needed factoring in of sustainability in business decisions.   The many reliefs combined with unclarity of what fair presentation entails in an impact context, brings the risk that the standard opens itself to abuse by those not acting in good faith or those with limited faith in the value of the reporting exercise, thereby ultimately hindering the ability of the measure to achieve its stated sustainability objectives. Therefore the importance of the fair presentation principle needs to be stressed and underpinned and further reliefs than IFRS should be avoided."]
["Survey","Danish Institute for Human Rights ","NGO","Denmark","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","DIHR supports this changed threshold and finds it both simpler than the previous version as well as an improvement in substance as some companies, due to their business models, were disclosing employee information on very few countries despite being present in very many/ having very large employment numbers. The set 1 approach in other words allowed (some) companies to only disclose a fraction of their total employees. Country level breakdowns are helpful contextual information for users that can qualify the reading and interpretation of the remaining S1 disclosures."]
["Survey","Danish Institute for Human Rights ","NGO","Denmark","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","For S1-S4 disclosures 1-4 DIHR could support the suggested amendments, but wants to flag that these standards are now very slim and that any further reduction of them risk rendering them hollow, undercutting their alignment with international standards on business and human rights and removing their utility to function as an envisaged disclosure vehicle for CSDDD.   Furthermore, DIHR strongly recommends to include metric disclosure directly in standards S2-S4 disclosure requirement 4 on targets. This to ensure consistency with GDR-M and compensate for these being the only topical standards without predetermined metrics. Inspiration can be found in E4-5 para 21."]
["Survey","Verisure","Preparer (non-financial preparing a sustainability report)","Switzerland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Major comment: 1. Paragraph 17. This point is still a problem in terms of disclosure - can we report goals regarding different pillars insted of a link to significant groups of products and/or services? 2. Paragraph 18. Value Chain's description tends to be broader - shall we guess we only have to report the main phases of the VC? 3. AR 7 for par. 17(b). what's the point of this? How would be this point audited?"]
["Survey","Dutch Authority for the Financial Market (AFM","National supervisory authority & regulator","Netherlands","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The AFM commends EFRAG for the simplifications it proposed while keeping most key elements crucial to the Green Deal objectives in place. We do however see two important elements which are currently missing in the revised ESRS, relating to the environmental topics E1-E5 and one element for potential (Social Standards) further simplification."]
["Survey","Dutch Authority for the Financial Market (AFM","National supervisory authority & regulator","Netherlands","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to previous comment on location centered approach"]
["Survey","Dutch Authority for the Financial Market (AFM","National supervisory authority & regulator","Netherlands","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Refer to previous comment on room for improvement."]
["Survey","Compagnie Nationale des Commissaires aux Comptes","Auditor","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","Consistently with the views expressed under question 17 above, we express concerns regarding the interaction of § 91 with the general relief relating to \"undue cost or effort\". In particular, it is unclear whether the relief for metrics presented under this paragraph and allowing to report only a partial scope is a practical application of the general relief presented under chapter 7.3 or not. It seems to refer more to \"impracticability\" which is a different concept from \"undue cost or effort\". It is therefore unclear under which circumstances such relief for metrics will be applicable. We suggest clarifying in the standard that the relief for partial scope disclosures is applicable when both direct and estimated data are not available without undue cost or efforts. It should not be used to justify the absence of information or to bypass the use of estimates.  It is also unclear how this relief for metrics interacts with the relief on acquisitions granted under § 72 in ESRS 1. Does the relief allow deferral of the integration of acquired business even if the information is available without undue cost or efforts, or does it apply only if the information on acquisitions cannot be obtained without undue cost or effort?  Besides, EFRAG should ensure that the relief, if any, applicable to the information on GHG emissions under DR E1-6, be presented in a clear and consistent way, which is currently not the case as the exception under § 91 contradicts § 87 (d). Under §87, the \"undue cost or effort\" relief seems to be, without further specifications, a general provision which would apply to all DRs, therefore including DR E1-6 GHG emissions. However, the relief in §91 on a partial scope explicitly states that this possibility is not available when reporting DR E1-6."]
["Survey","Compagnie Nationale des Commissaires aux Comptes","Auditor","France","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","Overall, we welcome the simplification and restructuring work of ESRS 2 performed by EFRAG, in particular the emphasis put on relevant disclosures at an appropriate level of aggregation, the reduction of the overlaps between the different DPs as well as the revamping of the DRs and notably SBM-3, IRO-1 and IRO-2. In addition to (i) the restructuring of the architecture and interaction between ESRS 2 and topical standards (see question 14) and (ii) the relief for anticipated financial effects (see question 19), we have provided detailed suggestions and comments to further clarify the Standard in the Excel template."]
["Survey","Compagnie Nationale des Commissaires aux Comptes","Auditor","France","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","The simplified structure and requirements are welcome, and we did not raise detailed technical objections. That said, the overall robustness of disclosures will depend on the future development of methodologies to capture location-specific impacts and risks, which remain essential to decision-usefulness."]
["Survey","Compagnie Nationale des Commissaires aux Comptes","Auditor","France","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We overall welcome the simplification and reorganization work of ESRS G1 performed by EFRAG, in particular the alignment of the structure with other topical Standards, which significantly enhances the readability and understandability of the Standard. Further clarifications could, however, be brought with respect to a targeted list of DPs in order to further reduce the complexity of implementing ESRS G1 and to ensure comparability in reporting. Detailed comments are included to that end in the Excel template."]
["Survey","Eurelectric","Business association (other than association of financial institution)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","Although option 1 would be more aligned with IFRS, we disagree with this option since it would imply an excessive burden.  We instead prefer Option 2 as it can relieve companies from the challenge of disclosing quantitative and commercially sensitive information. However, not being aligned with IFRS standards, Option 2 might also pose challenges of inconsistency and of duplication burden for companies that report under both frameworks.  Hence, we call for a version of Option 2 that (i) mitigates inconsistency, (ii) avoids duplicate reporting of the same information, (iii) provides clear guidance on what constitutes an acceptable qualitative disclosure (examples, minimum elements, etc), (iv) encourages voluntary quantitative figures if material and reliable."]
["Survey","Eurelectric","Business association (other than association of financial institution)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","The disclosure requirements remain largely unchanged. Hence, we call for a further simplification, for example by removing the need to split of assets before and after actions. ESRS should also be structured so that companies applying them can also fulfil the IFRS reporting requirements.",null,null,""]
["Survey","Eurelectric","Business association (other than association of financial institution)","Belgium","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","While qualitative information on payment practices is relevant to indicate how the protection of SME's is tackled within the company, the calculation of G1-6 metrics is overly complex for international groups operating with a great variety of payment standards. We therefore support simplification by deletion of the quantitative datapoints G1-6 paragraph 20 (a)(b)."]
["Survey","Eurelectric","Business association (other than association of financial institution)","Belgium","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We welcome the significant reduction of overlaps within ESRS S1. Removing redundancies improves the clarity and usability of the standard, making it easier for companies to prepare sustainability reports and for users to navigate and interpret the disclosed information. This simplification supports a more efficient reporting process and enhances the overall coherence of the sustainability statement.  Moreover, we have the following comments on specific data points.  DP 55a (now 25) Characteristics of non-employees in the undertaking's own workforce: it should be specified that contractors are not own workforce  DP 97b (now 44b) Remuneration metrics: we call for allowing companies flexibility in interpreting the specific calculation of the median and which group of workers to include.  DP 97a (now 44a); DP 98 (now moved to [NMIG 35]) Gender Equality and Diversity: we welcome that requirements are aligned with the Pay Transparency Directive, as long as companies are allowed flexibility in interpreting the calculation methods.  DPs 93a, 93b Work-Life Balance: we call for allowing companies flexibility in interpreting the group representing the 100% base and the type of leaves included."]
["Survey","Eurelectric","Business association (other than association of financial institution)","Belgium","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome the explicit reference to ESRS 2 within ESRS S2, as it reinforces the connection between general disclosure requirements and topical standards, contributing to a more coherent reporting framework. We also note the improved clarity regarding vulnerable stakeholders. This enhancement helps companies better identify and disclose impacts on stakeholders who may be most affected by their activities, supporting more targeted and meaningful reporting."]
["Survey","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","While consolidating SFDR datapoints in ESRS 2 improves traceability, it still imposes additional requirements linked to other EU frameworks. Simplification should focus on limiting duplication and only requiring datapoints that are material, to avoid unnecessary reporting."]
["Survey","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","AR 26 should be reviewed to avoid overly prescriptive disclosures on biodiversity targets. Suggested wording: \"Undertakings may, where relevant, describe biodiversity and ecosystem targets, including scope, baseline, and timeframe.\" It would also be preferable to make the relevant methodology more concrete as biodiversity is still a relatively vague topic to report on."]
["Survey","ShareAction","NGO","United Kingdom","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","We are concerned that this clause could potentially become an excuse to omit critical data, weakening the transparency and comparability of sustainability information. We believe that companies should not be allowed to use poor data availability as a reason to avoid addressing Scope 3 emissions. While we are not necessarily calling for ESRS to impose explicit requirements on Scope 3 calculation methods, we believe it would be useful to highlight good practice — for example, starting with spend-based estimates and then engaging suppliers and customers to improve data quality over time. Companies have cited data gaps and cost concerns for years without presenting clear timelines for improvement or showing progress. Allowing open-ended relief on Scope 3 reporting would give companies excessive leeway and risk delaying meaningful action."]
["Survey","ShareAction","NGO","United Kingdom","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","ESRS, being based on the materiality principle, the CSRD requirement to disclose impacts, risks and opportunities and their management, and the general principles of the Accounting Directive, has already been subject to a fair presentation regime. Making it explicit helps to clarify it.   It provides companies with clarity on the discretion and judgement, as well as related safeguard, they are expected to exercise when applying the standards. "]
["Survey","ShareAction","NGO","United Kingdom","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","The removal of paragraph 14 can be easily compensated by adding a reference to SMEs in the description of the topics in ESRS 1, Appendix A, and in ESRS G1, paragraph 4.    The removal of datapoint originally located in para 33(a) concerning average days it takes to pay an invoice, does not seem to be necessary for the reduction of burden. The undertaking would still need to collect this data to be able to meet the other requirements, in particular the calculation of the % of its payment aligned with its standard payment terms (in para 20(a)). "]
["Survey","ShareAction","NGO","United Kingdom","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","Danish National Funding Mechanism","(National) standard setter","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We partially agree. The provided flexibility is appreciated and important to provide relevant and easily accessible information to the primary user groups. We have identified the following measures to further enhance the flexibility and the relevance:  Structure of the reporting:  We suggest providing flexibility in the order of the E, S and G-sections (ESRS.1-105) as this would allow preparers to present the information more logically based on its business model and provide enhanced readability and accessible information for the primary users. This is particularly important when the social aspects are the most important to the reporting entity.   We support the introduction of appendices (ESRS1-105+110), but suggest, further flexibility in location of appendices and extensive tables, e.g., allowing for a part 2 of the sustainability report located after the financial section (provided this is allowed under national legislation) as this provide clarity in the reporting.  Incorporation by reference: We believe the requirements on \"incorporation by reference\" (ESRS1-9.3) should be less granular for ESRS 2, allowing for DR-references to the relevant (sub)section in the management review, e.g., \"ESRS2-GOV1 is incorporated in section xxx of the management report\". The practical solution on identifying sections with different levels of assurance should be left to the preparers and auditors.   This would support better integration of, e.g. strategy, business model and the governance-information with the counterparts in the management report.  Non-material information: We support the possibility to provide non-material information (ESRS.1-108) to meet the needs of specific stakeholders, when clearly labelled as non-material information. However, we believe the requirement for non-material information to provide a faithful representation (ESRS.1-108(b)) should be deleted as this goes beyond relevant criteria for such information, and that the requirement (108(a)) on non-obscuring is sufficient."]
["Survey","Danish National Funding Mechanism","(National) standard setter","Denmark","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We understand that this question addresses section 7.4 and ESRS1-91 in particular  We support the relief proposed in ESRS1-91 and see no need for a time limit. Estimates shall meet the qualitative criteria of faithful representation, and QC9 clearly states that information can be accurate without being perfectly precise in all respects. For this reason, we suggest extending the relief to cover GHG emissions as well. The E1-6 exclusion is not justified and should be deleted.  The incorporation of this relief is clearly positive, but it should be acknowledged that some data may be permanently unavailable, especially given the expected significantly reduced CSRD scope due to the omnibus, and that this is beyond the company's control. Therefore, there should not be a time limit to the relief.   Furthermore, we believe this evaluation is not needed yearly, depending on the specific metrics and the nature/reasoning for data either not being available or for the use of estimates. We believe the principle in ESRS1-89 grasps this as it indicates that the assessment can change over time as circumstances change and hence the formulation of the last sentence in ESRS1-91 needs to be adjusted accordingly.  Finally, the standards clearly state that they do not impose behavioral - or conduct requirements, only disclosure requirements. Hence, there is no requirement to cease cooperation if the counterparty cannot or will not provide data. The relief for missing data should be applied consistently regardless of the disclosure type."]
["Survey","Danish National Funding Mechanism","(National) standard setter","Denmark","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","While we support the total reduction of disclosures by 68%, we see a need to stress that there is no 1:1 correlation between these numbers and the actual burden reductions for reporting entities. Based on our analysis and discussions with several of the largest Danish entities, their analysis and initial assessment of applying the amended standards, it is our conclusion that the draft standards will only result in very limited administrative burden reductions for reporting entities – only around 5-10 pct.    The reduction in data points must also materialize in actual burden reductions, to ensure the Omnibus ambitions are met. We find that further burden reduction is possible while maintaining transparency in support of the EU green Deal and without impairing the needed data infrastructure to requirements for the financial sector in SFDR, CRR, Pillar 3 etc. We suggest considering further reduction in the mandatory datapoints for instance by removing granularity, in particular in S1.  Furthermore, we suggest adding additional guidance to the assessment of materiality of information described in ESRS 1, section 3.1 or 3.6, making it easier for the preparer to deem information non-material taking the characteristics of the IRO into consideration, e.g. considering whether it is actual or potential, or material due to scale or scope being most important. This would be particularly relevant for the IROs that \"only just\" met the threshold set in accordance with ESRS 1, para. 28, and would – besides reducing the reporting burden – provide a more focused and decision-useful report. This also links to our comments relating to policies in Q14 that illustrate this point."]
["Survey","Danish National Funding Mechanism","(National) standard setter","Denmark","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","As indicated in the above responses, starting in Q11, we believe ESRS 1 - and in particular the DMA process -  while revised have not amended the fundamentals. We refer to the detailed comments in the other questions.   Furthermore, we would like to highlight the importance of the need to delimit value chain reporting for financial institutions as well as resolving the issues for Investment Holding Companies. If no solution is provided at level 1, there is as a minimum a need for a general provision in ESRS 1 that allows financial institutions to adapt their sustainability reporting, including value chain reporting, to the specificities of financial institutions and that the issues around business model is addressed for the Investment Holding Companies to ensure that the qualitative criteria of relevance and reliability are satisfied for these types of entities."]
["Survey","Danish National Funding Mechanism","(National) standard setter","Denmark","35.ESRS1_7.3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Partially agree Paragraphs are widespread on sources of information expected used, e.g. ESRS 1, paragraph-27, 47, and 62, and various paragraphs mentioning the undue cost or effort relief, e.g. ESRS 1, paragraph-47, 60, and 87-89. A gathering of these paragraphs in sub-chapter 7.3 may avoid different interpretations as to what applies when, e.g. whether data available in-house shall be used in ESRS 1, paragraph 65.","ESRS1","7.3 Use of reasonable and supportable information that is available without undue cost or effort 18",""]
["Survey","EFFAS e.V.","User Association","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","It is essential to adopt Option 1 for several reasons.  First, Option 1 preserves the requirement to provide both qualitative and quantitative information, while offering pragmatic relief when reliable measurement is not possible or uncertainty is too high. This mirrors the IFRS relief in IFRS S1/S2, ensuring interoperability between ESRS and global standards. By contrast, Option 2 would create a fundamental disconnect with IFRS and undermine comparability for multinational investors.  Second, conditional quantitative disclosures are necessary for the objectives of the SFDR and the European Commission's sustainable finance agenda. These frameworks seek to influence capital allocation by giving investors decision-useful data on the financial effects of sustainability matters. Under Option 2, companies could omit quantitative information entirely, leaving investors without a basis to assess exposure and resilience. This would send the wrong signal: that the EU is retreating from transparency rather than reinforcing it.  It is hard to accept that a company can label a sustainability topic as material while providing no quantitative estimates of its financial effects. Material matters must meaningfully affect performance, position, or prospects, so management should have at least an approximate sense of magnitude or direction. Stopping at qualitative descriptions would undermine the credibility of materiality assessments, leave investors without key information, and create an inconsistency between identifying a topic as material and providing no measurable implications. Quantitative disclosures are essential to uphold both the integrity of double materiality and the usefulness of information for decision-making.  Adopting Option 2 would risk reducing sustainability reporting to narrative alone, depriving investors of the hard data needed for portfolio construction, risk management, and stewardship. It would weaken the European reporting regime and reduce its impact on directing capital toward sustainable activities.  For these reasons, Option 1 strikes the right balance between feasibility, global alignment, and investor usefulness."]
["Survey","EFFAS e.V.","User Association","Germany","22.S2","Comments on deleted datapoints in ESRS S2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","EFFAS calls for explicit coverage of ESG-linked remuneration for senior management under ESRS 2 Governance, extending beyond board members to ensure full alignment of incentives with sustainability objectives and in coherence with the governance duties established under the CSDDD. Finally, the adoption of the VSME standard for SMEs in the supply chain, supported by digital data collection, is essential to safeguard proportionality while maintaining interoperability and data reliability."]
["Survey","AFG (Association Française de la Gestion d'actifs)","Association of financial institutions","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","AFG welcomes the simplification proposals and the creation of the Non-Mandatory Illustrative Guidance (NMIG).   However, we wish to draw your attention to the following points: - The risk of overinterpretation that these NMIG may entail, whether by certain stakeholders or by auditors. - The risk that these optional standards may become, or revert to, mandatory requirements. The creation of this \"category\" of standards runs counter to the simplification objective. The EFRAG should take a more prescriptive approach to methodology to enhance comparability, rather than relying on optional guidance. Moreover, there is a lack of clarity regarding the practicality of these elements.  AFG requests clarification on the intended final use of this guidance, its legal status, and a clear statement that these are non-mandatory standards, whose sole purpose is to clarify mandatory DP requirements, and that the Non-Mandatory Illustrative Guidance is not intended to become mandatory elements for preparers of sustainability reports."]
["Survey","AFG (Association Française de la Gestion d'actifs)","Association of financial institutions","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","AFG (Association Française de la Gestion d'actifs)","Association of financial institutions","France","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We remind our support for the extraterritoriality and the necessity for France to keep her sustainable leadership on the world wide's vision. We support the proposal from ANC to introduce an exception in the AR for financial institutions' absolute climate reduction targets, allowing disclosure of intensity-based targets provided they disclose contextual information and the potential trend in absolute value.   The intensity target is more representative than the absolute target for investors, especially when it comes to setting targets. An absolute result makes less sense for financial analysis. If Europe is the only continent requiring this information as an absolute target, it will be problematic for European investors, who are subject to KPI disclosure requirements under other regulations (e.g., SFDR).  So we support the ANC proposal wording: AR X for §E1-6 §26a on target setting or Amendment to AR12 for para 26: \"Financial institutions may disclose targets in intensity value with (a) a breaking-down per high-climate impact sectors for which it has set targets, (b) a concise indication on the trend of absolute emissions per target\".  Adaptation of concepts and lexicon, clarifications regarding (i) double materiality assessment and (ii) value chains considerations, links with sectorial regulations"]
["Survey","AFG (Association Française de la Gestion d'actifs)","Association of financial institutions","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"ESRS E1 on net zero targets:  We note that the reference to net zero has been completely removed from the standard. This is regrettable, as prior to ESRS, there was a significant proliferation of net zero communications, each with varying levels of ambition. Such claims were also identified by ESMA in its greenwashing report as a prevalent issue. The inclusion of net zero in Set 1 provided a clear, uniform definition for all actors and led to substantial improvements in disclosure quality and better differentiation from neutrality claims. This concept and its definition should be maintained in the standard.  Proposed wording: Add in glossary previous entry \"Net-zero target\" Retain current Set 1 E1-7 §60 with clarifications regarding removals vs offsets: \"In the case where the undertaking discloses a net-zero target in addition to the gross GHG emission reduction targets in accordance with Disclosure Requirement E1-6, it shall explain the scope, methodologies and frameworks applied and how the residual GHG emissions (after approximately 90-95% of GHG emission reduction with the possibility for justified sectoral variations in line with a recognised sectoral decarbonisation pathway) are intended to be neutralised by GHG removals.  Comparability with preceeding reporting periods:  To ensure comparability over time, undertakings should be required to make available, on a dedicated section of their website, all the sustainability statements their prepared in application of the CSRD.  Proposal for the presentation of sustainability statements:  To offset the potential loss of comparability that may result from granting flexibility to reporting entities, we propose (aligned with the French Market Authority – AMF) a new numbering rule for the Disclosure Requirements to which the information relates. This approach, which reflects a good practice observed in financial reporting, would allow for more efficient retrieval of information."]
["Survey","Stakeholder Reporting Committee (European Accounting Association)","Academia","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Comment on Q11 subquestions:  Q11.1. To reduce heterogeneous interpretations, we recommend setting minimum criteria for selecting top-down vs bottom-up approaches. An operational note should require documentation of: (i) the initial universe of topics/IROs, (ii) severity/likelihood thresholds per topic, and (iii) sources of evidence and/or stakeholders consulted. This balances simplification with traceability. Q11.2. Regarding paragraph 21.a), we propose re-phrasing \"general-purpose financial reports\" to \"general-purpose annual reports\" and deleting \"including financial statements and the sustainability statement.\" Q11.3. We recommend requiring a simplified table linking each material IRO to related disclosures/DPs, metrics/targets, and policies/actions. Q11.4. Specific users (e.g., rating agencies) might seek datapoints that are not reported. Firms may introduce a numerical threshold to determine material topics and this could result in certain issues being excluded from \"material information\" solely because their amounts are considered insignificant. Allowing organisations to include such \"quasi-material\" topics ensures that relevant information is not overlooked. Q11.5. This \"statement of compliance,\" together with paragraph 109 — which allows firms to include an executive summary highlighting key messages about their material environmental, social, and governance impacts, risks, opportunities, and related management — enables the creation of a report in which the \"compliance\" sections and the more \"strategic\" parts are clearly distinguishable, thereby improving readability. Q11.6. We have reviewed the \"Comment/Rationale\" related to this change (revised paragraph 22) in the document LOG OF AMENDMENTS ESRS 1 GENERAL REQUIREMENTS and found the explanation particularly helpful. We suggest considering its inclusion directly in the standard to provide clearer guidance on what is expected. Q11.7. The text \"This Appendix is an integral part of ESRS 1 and provides nonbinding guidance to support the application of provisions in this Standard\" is confusing because ESRS 1 is mandatory but Appendix A that is an integral part of ESRS1 is not mandatory. Please clarify."]
["Survey","Universidad de Burgos","Academia","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The amendment is generally reasonable. But the \"undue cost or effort\" principle is too broad, as indicated in the response to question 19."]
["Survey","Universidad de Burgos","Academia","Spain","22.E4.","Comments on deleted datapoints in ESRS E4","I partially agree and partially disagree","The simplification proposal is depriving users of the sustainability report from information. However, given the EU mandate the proposal has achieved a reasonable balance."]
["Survey","Universidad de Burgos","Academia","Spain","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","The simplification proposal is depriving users of the sustainability report from information. However, given the EU mandate the proposal has achieved a reasonable balance."]
["Survey","Universidad de Burgos","Academia","Spain","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I disagree","The \"consolidation\" and reduction of DPs results in a loss of granularity and breaks the traceability necessary for the SFDR to inform investors.  Merging eight DPs into a single \"HR policy\" in ESRS 2 limits the relevance of human rights, erases nuances by stakeholder group, and weakens operational alignment with UNGP/OECD.  The single \"severe cases\" indicator fails to capture typologies, severity, remediation, or geography.  Excluding \"fatalities\" from the scope of the PAI on lost days is a material setback. Investors require explicit visibility into fatalities, rates, and trends.  Moving content to ESRS 2 (general) instead of maintaining it in ESRS S1–S4 reduces consistency between IROs and specific metrics and hinders insurability.  The supposedly \"marginal\" reduction in coverage is, in fact, material for time series, benchmarking, and alignment with the SFDR Annex I tables; it increases the risk of cherry-picking and mapping gaps."]
["Survey","Universidad de Burgos","Academia","Spain","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Some emission-intensity datapoints have been trimmed. While intensity indicators are valuable to users, the cuts mainly target metrics that can be derived from other reported figures (e.g., emissions relative to revenue or total assets). We advocate preserving at least one sector-relevant intensity indicator, since stakeholders need both absolute and intensity perspectives—aligned with TCFD guidance on Metrics & Targets.  On transition plans, we welcome the draft's explicit alignment with EU and international climate objectives."]
["Survey","Universidad de Burgos","Academia","Spain","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Some emission-intensity datapoints have been trimmed. While intensity indicators are valuable to users, the cuts mainly target metrics that can be derived from other reported figures (e.g., emissions relative to revenue or total assets). We advocate preserving at least one sector-relevant intensity indicator, since stakeholders need both absolute and intensity perspectives—aligned with TCFD guidance on Metrics & Targets.  On transition plans, we welcome the draft's explicit alignment with EU and international climate objectives."]
["Survey","ANSA","Business association (other than association of financial institution)","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The right direction for improvement is to enhance the connection between the PAT disclosure and the IRO description. It will also be beneficial to allow disclosure at a higher level of aggregation than the material IROs. This is because the management of IROs at an aggregate level could better reflect the most important issues that the company must deal with globally."]
["Survey","ANSA","Business association (other than association of financial institution)","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","ANSA","Business association (other than association of financial institution)","France","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","Simplification is one issue to consider, but it must also take into account information that is not too complex to provide, but which could threaten the company's future."]
["Survey","ANSA","Business association (other than association of financial institution)","France","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","We believe it is important to keep the possibility of amending these issues open, given that we are strongly calling for SFDR requirements to be simplified and reduced."]
["Survey","ZVEI e.V.","Business association (other than association of financial institution)","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","New Paragraphs provide helpful clarifications, but significant concerns remain about complexity and feasibility in practice.  Positive aspects: •\tThe guidance on distinguishing actual vs. potential impacts is useful and welcomed. However 3.3.1 (35) lacks clarity in several areas, creating potential confusion for firms. For example: What defines a \"significant\" mitigation or prevention action, and when is it not considered significant? Clearer definitions and concrete examples are needed to avoid unnecessary and lengthy discussions with the auditor about interpretations. •\tThe clarification that remediation measures may be considered when assessing risks is a positive step, as it may reduce material risks and the related reporting effort. •\tAllowing consideration of actions that reduce the severity or likelihood of potential negative impacts reflects company practice and is in line with established risk management approaches. Concerns and challenges: •\tThe gross approach for potential impacts with ongoing mitigation may lead to overreporting. •\tThe guidance adds significant complexity to the DMA process, especially for smaller or less mature reporters. Current software tools cannot meaningfully map these requirements, creating practical difficulties for companies and auditors. •\tAppendix C attempts to address the gross vs. net issue, but in practice it requires companies to assess each negative impact in detail. This is unlikely to simplify reporting and may not be feasible beyond manual solutions. We therefore recommend to delete Appendix C. •\t. Further considerations: •\tExcluding compliance with legal and regulatory requirements as a \"positive impact\" risks undervaluing the strategic role of regulation. For many companies, regulatory frameworks are not merely minimum standards but central guides for sustainable action. •\tIt is unclear whether globally valid guidelines remain acceptable as a mitigating factor under ESRS 1.36."]
["Survey","ZVEI e.V.","Business association (other than association of financial institution)","Germany","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","The amendments contribute to a more effective and relevant materiality filter overall, but the concept of fair presentation requires clearer definitions and practical guidance to avoid disputes, ensure consistent application, and safeguard auditability. Without these clarifications, the risk remains that simplification could lead to inconsistent reporting rather than improved relevance. Positive aspects: •\tThe simplification and stronger risk-based approach are welcome and will reduce reporting burden by focusing on genuinely material topics. •\tInternal costs and efforts can be reduced, while the amendments provide clearer guidance for companies subject to ESRS. •\tThe principle of fair presentation is positive in theory and helps avoid excessive reported information. Concerns and limitations: •\tFinancial adequacy: Without clearer definitions, there is a risk of oversimplified or even misleading reporting, as well as disputes with auditors. •\tAuditor diligence: Applying fair presentation consistently will be challenging, and it may become more difficult for auditors to demonstrate due diligence. •\tInterpretation risks: Non-finance employees are often less familiar with this principle, which could lead to uncertainty and inconsistent application. Additional elaboration in sector-specific standards would help reduce room for interpretation. •\tAdded value: In practice, the principle may not provide significant additional benefit, as disclosures are already strongly determined by the outcomes of the materiality analysis itself. •\tThe definition of when information is material is very broad. Not only are primary users not further defined but point (b) „users of general purpose\" opens the discussion on what constitutes material information (especially against the fair presentation principle) even further, as anybody could be a user and might not „feel fairly representative\". The \"fair presentation\" concept needs a precise definition to avoid subjectivity and minimize audit burden."]
["Survey","ZVEI e.V.","Business association (other than association of financial institution)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","ZVEI e.V.","Business association (other than association of financial institution)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","S1-DR10 Social Protection This disclosure requirement requires international companies to collect data about the legal situation in all countries where they have employment. What is understood by e. g. maternity protection and parental leave is assessed very differently depending on the country and region. It cannot be ruled out that, for this reason, the legal situation for social security is assessed differently by various reporting companies in each country. To ensure the comparability of the data, information on the legal situation in each country worldwide should be made centrally available to companies. On this basis, companies should then report whether they compensate for insufficient social security in a country where they have employees through their own accompanying measures.  S1-DR15 Remuneration Metrics 44b) In international companies, the annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees is significantly influenced by the distribution of the workforce around the world. In European companies, top managers and CEOs who might be those \"highest paid individuals\" in many cases tend to be located in Europe whereas e.g. production lines might be located in low cost countries. Even if the workers in those countries might be paid a fair wage, and even if the \"highest paid individual\" might receive just an average remuneration, this ratio might indicate a severe disproportion although the remuneration for all employees is adequate. In a company with employment exclusively in Europe, however, the same figure might be an indicator for an improper high remuneration of the top earner. So this KPI is not comparable for different companies and should be omitted."]
["Survey","Eurosif - the European Sustainable Investment Forum","User Association","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","We agree with the overall approach of simplifying and shortening the standards by removing duplications between ESRS 2 and topical standards, as it can reduce burden while maintaining much of the necessary content. We also support the renaming of the minimum disclosure requirements to general disclosure requirements.   AR 24 for §28 a: we agree that disclosing IROs and PATs at the level at which the IROs are managed can simplify the standards.  AR 27 for §30: we underline that it is essential that companies provide a detailed explanation as to why PATs would not be developed for material risks and impacts. Additionally, we strongly encourage maintaining the disclosure related to whether companies plan to develop PATs in the future and the timeline for this development. This information provides useful insights as to whether companies consider these IROs as less critical compared to others, or whether their absence constitutes an oversight from the companies."]
["Survey","Eurosif - the European Sustainable Investment Forum","User Association","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We are concerned with the suggestions to water down the disclosures on anticipated financial effects.   Quantitative anticipated financial effects are one of the core pieces of information for investors and are essential for assessing financial materiality. In the development of the ESRS, it has been a priority to provide investors with this data, which is a fundamental requirement for managing the risks in their portfolios. We acknowledge that there can be challenges connected to producing this information, however the effort is worth the benefit for a company, its investors and the wider economy. Understanding these often-existential risks is necessary for resilience both at the level of the enterprise, and the economy as a whole.   While Option 1 offers broad reliefs, we believe it could be a workable compromise in the spirit of simplifying the ESRS for preparers, subject to the caveats mentioned previously (see response to Q.17-18). Of the two suggested options, Option 1 is the only one to maintain the credibility of the ESRS – clearly establishing the expectation to provide quantitative data to users, while granting adequate reliefs for reporting companies when they encounter legitimate challenges to do so.   Option 2 would entail a complete removal of the quantitative disclosures and leave companies able to choose the data to provide based on convenience rather than materiality or relevance, thus leading to critical loss of data and creating information gaps for investors that would undermine the consistency and reliability of the standards.  Option 2 would also introduce reliefs that go beyond the ISSB standards, which would mean more effort for companies that report under both the ISSB and ESRS frameworks, and difficulties for investors that want to compare reports between both regimes. Option 1, while not being entirely aligned with the ISSB standards, would mitigate this fragmentation."]
["Survey","Eurosif - the European Sustainable Investment Forum","User Association","Belgium","22.S1","Comments on deleted datapoints in ESRS S1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Eurosif conducted a broad consultation exercise across its members and partners to identify which data points investors consider as essential to maintain. The following deleted datapoints were highlighted as relevant due to their usefulness for investors:  Mandatory data points: S1-6_13 50 d S1-6_16 50 e  Voluntary data points:  S1-6_08\t51 S1-14_08 89 S1-14_09 89 S1-14_10 90 S1-16_07 99"]
["Survey","Eurosif - the European Sustainable Investment Forum","User Association","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","While we appreciate the efforts to maintain the data points required under SFDR, some of the changes in the revised ESRS may create additional challenges for investors. It might become more difficult to find the relevant information in the sustainability reports and may induce additional challenges to calculate the metrics for SFDR.  The removal of intensity-based data points from the ESRS may therefore create issues in complying with SFDR, given that financial institutions will have to identify the relevant ESRS data points in the sustainability reports and calculate themselves the corresponding SFDR indicators. Furthermore, different calculation methods may result in inconsistencies between the metrics disclosed by companies, hindering comparability. For this reason, we would recommend that intensity metrics – in particular indicator 3 on Gross GHG emission intensity – be maintained in the ESRS.   Finally, the shift of indicators related to non-respect of UN GPs and OECD Guidelines on Multinational Enterprises to a footnote in another indicator may jeopardise the capacity of users to gather this information, which is required under a number of legislations including SFDR, BMR, but is also a basic information required for investors' exclusions policies."]
["Survey","Eurosif - the European Sustainable Investment Forum","User Association","Belgium","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Eurosif - the European Sustainable Investment Forum","User Association","Belgium","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Toulouse Business School","Academia","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","It is reasonable to include guidelines and examples on how to disclose datapoints in \"Non-Mandatory Illustrative Guidance\" (NMIG). However, the simplification proposal is depriving users of the sustainability report from crucial information to assess the due diligence of the company. For example, the policies to identify and manage actual or potential, positive or negative impacts on people or the environment, are crucial to assess due diligence. Therefore, it is paramount to perform an in-depth assessment to determine whether all disclosures currently presented in the NMIG should be made mandatory in the delegated act.  While the NMIG may reduce implementation questions, encourage proportional innovation, and ease the burden on PAT narratives when rigid prescriptions fail, it could also reduce comparability. Without a minimum common ground, methodological heterogeneity hinders cross-sectional and time-series analyses. In this regard, the NMIG is useful if it complements—not replaces—a clear regulatory baseline that preserves consistency, traceability, and insurability."]
["Survey","Toulouse Business School","Academia","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","The \"undue cost or effort\" principle is aligned with the goal of administrative simplification. However, the articulation of this \"relief\" in paragraph 89 ESRS1 is so imprecise that it may turn this set of standards into dead letter.   The \"undue cost or effort\" principle risks transforming Directive (EU) 2022/2464 into a voluntary guideline.  The limitation of considering resilience in terms of risks places an emphasis on financial materiality, overlooking how an organization's activities may also affect the resilience of the ecosystems in which it operates."]
["Survey","Toulouse Business School","Academia","France","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Complex estimates are common to all sectors. The financial sector has a disproportionate effect on climate change. Absolute targets are essential for assessing progress on climate change, and banks are no exception in this regard. This exclusion is also at odds with other information on climate change required by financial institutions in other EU regulations (e.g. SFDR) and by banking supervising entities (Basel Pillar III)."]
["Survey","Toulouse Business School","Academia","France","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Toulouse Business School","Academia","France","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","SPOLCHEMIE - Spolek pro chemickou a hutní výrobu","Preparer (non-financial preparing a sustainability report)","Czechia","35.ESRS1_1."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","•\tStandards must be clear, simple, unambiguous, and limit flexibility of interpretation.  •\tWe support launching with a minimalist version of ESRS for at least the first two years, and only tighten requirements later based on evaluation and evidence. •\tThe ESRS (as any other main regulation) should be established by EU regulation, not directive or delegated acts, to minimize divergent interpretations. •\tThe lifecycle of the ESRS (as any other main regulation) should be: define baseline scope, then after a predetermined period (e.g. 3–5 years) perform an evaluation, and only then adopt amendments. •\tWe oppose inclusion of voluntary disclosure allowances within the mandatory standard text; instead, any burdensome provisions should lead to specific reduction proposals. We propose creation of Non Mandatory Illustrative Guidance (NMIG) as a separate, supporting instrument and not legally binding provisions.  Note: Section on double materiality do not work and cannot be filled in. 3. Double materiality as the basis for sustainability reporting Impact materiality is currently too subjective, due to missing binding methodology and threshold definitions. •\tThe scale and detail of disclosures may vary widely across companies depending on the auditor, undermining cross market comparability. •\tWe propose a centralized database of examples (material vs non‐material) to support internal methodology and audit dialogue. •\tSome areas are already regulated at national level or internally well managed, with no prior negative impact; such areas often get classified \"not material,\" even though residual risks may exist (e.g. many topics in ESRS S1). •\tWe recommend eliminating financial materiality for non listed entities: lack of public demand, absence of standard tools/methods, and sensitivity of financial data make consistent, valuable disclosure impractical. •\tAlternatively, companies should be allowed to state that no financial materiality assessment has been performed, even at reputational risk, rather than forcing weak estimations.","ESRS1","1. ESRS Standards, reporting areas and drafting conventions",""]
["Survey","Sonae - SGPS, S.A","Preparer (non-financial preparing a sustainability report)","Portugal","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We recommend maintaining the disclosure specification on key relevant nature-related targets, ensuring alignment with key relevant frameworks particularly SBTN and the Global Biodiversity Framework"]
["Survey","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The \"may\" (voluntary) data points should not be eliminated. In many cases they are \"shall\" in GRI standards, so it is important to keep them to align with GRI standards. Also, many of them were originally proposed as mandatory by EFRAG to the EC. The first wave of reports show that many companies have reported some \"may\" data points. Retaining them would help ensure standardization/comparability between company reports. Almost all of the datapoints for non-employee workers are voluntary, thus most datapoints for this vulnerable group of workers has been lost. Also, important datapoints on full time versus part time workers has been eliminated."]
["Survey","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","The new, simplified framework makes it easier for companies to report on these SFDR-related matters in a way that corresponds to how their policies are set. For users, this consolidation makes it easier to locate the relevant information. However, the SFDR datapoints are very helpful and should only selectively be amended"]
["Survey","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","The unadjusted gender pay gap should be kept as mandatory, since the methodology for calculating it is clear. The adjusted pay gap figure as voluntary. In practice many companies are reporting both figures, which is useful for improved transparency. However, since the methodology for calculating the adjusted figure is not standardized, the unadjusted should be kept mandatory."]
["Survey","Datamaran","User (analyst, data provider, rating agency, etc.)","United Kingdom","35.ESRS1_3.5."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Given their abstraction, the effectiveness of those principles dressed as practical considerations remains a question mark, especially considering the overreaching attitude auditors adopted in providing assurance to Wave 1 CSRD statements.  ESRS 1 48 and related application requirements then introduce measures through which \"the undertaking may avoid unnecessary complexity\". The formulation based on \"may\" rather than \"shall\" already downgrades those measures to optional ones, which some auditors may interpret as: \"only certain companies may use the lighter process described in ESRS 1 48, and there have to be companies out there that, in light of their complexity, reach, size, must do more than that\".  Similarly, AR 17 does nothing to remove the ambiguity: \"The undertaking may adopt a top-down or a bottom-up approach to perform its materiality assessment.\" This is really puzzling, considering the follow-up comment: \"Adopting a top-down approach may be more pragmatic and reduce the complexity of the process, and is expected to lead to the same outcome of the materiality assessment as the bottom-up approach.\" If that is the case, why on earth is the bottom-up approach still in the standards? Its presence, together with the \"may\" based language of these provisions, leaves a back door open to auditors to ask for a bottom-up approach whenever they deem it appropriate. More worryingly, one practitioner highlighted to me that certain auditors may even interpret this AR as a stress test, asking the reporting company to conduct both the top-down and bottom-up approaches and check that the results effectively match.  Additionally, AR 18 is worded in a highly problematic way. While a) and b) are welcome clarifications that can be used to effectively push back on certain auditors' literal interpretation of the standards, making those 2 measures conditional on the ambiguous \"unless more investigation is necessary\" reduces their reach.","ESRS1","3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported",""]
["Survey","We Mean Business Coalition","NGO","Switzerland","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","First and foremost, we support the NMIG not being part of the ESRS DA. We suggest finalising this guidance at a later stage to incorporate guidance from feedback received from this consultation as well as the final DA after the EC's revision and adoption. However, we also suggest that EFRAG clarify the legal role of the original supporting materials (e.g., the Q&As published for the original ESRS) and, for example, either retire or supersede them.  It is also important to bring order to the due process of this ecosystem by clarifying the legal status and hierarchy of all guidance, as well as the due process followed—particularly for updates of these documents. There is no need to replicate the legal complexity created for the EU Taxonomy by the Platform and the EC with their endless FAQs; this should certainly not be a model to aim for."]
["Survey","We Mean Business Coalition","NGO","Switzerland","22.E1.","Comments on deleted datapoints in ESRS E1","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","OK"]
["Survey","We Mean Business Coalition","NGO","Switzerland","22.S4","Comments on deleted datapoints in ESRS S4","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","OK"]
["Survey","We Mean Business Coalition","NGO","Switzerland","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","We Mean Business Coalition","NGO","Switzerland","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See previous replies"]
["Survey","We Mean Business Coalition","NGO","Switzerland","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","EPRA (European Public Real Estate Association)","Business association (other than association of financial institution)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","EPRA welcomes the streamlining of the DMA. EFRAG's clarified requirements align with our own approach: in 2024, we introduced a materiality process tailored to listed real estate and based with the original sector agnostic ESRS. We believe the ESRS should remain high level, while ensuring clarity and consistency."]
["Survey","EPRA (European Public Real Estate Association)","Business association (other than association of financial institution)","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","EPRA (European Public Real Estate Association)","Business association (other than association of financial institution)","Belgium","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree"]
["Survey","Oesterreichs Energie (association of Austrian electricity companies","Business association (other than association of financial institution)","Austria","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"ESRS1  ESRS 1 amend: („necessary for users […] to understand the undertaking's material impacts, risks and opportunities…\", vgl. ESRS 1.21(b) amend, S.14). According to this proposal, the significance of information depends on whether a user considers it necessary to understand the company's key reporting objectives. However, there are no clear assumptions about user groups (e.g., their prior knowledge) or criteria for determining when information is considered necessary for them. This could mean that this unclear requirement for the materiality of information does not lead to a limitation, but potentially to an indefinite expansion of reporting requirements. There should be clearer guidance on materiality analysis to distinguish between actual and potential impacts, as the current proposal does not sufficiently clarify this important distinction.  ESRS2  EFRAG is consulting on two options (p.26).  The quantitative disclosures on the expected financial effects required under option 1 are subject to considerable uncertainty. Furthermore, such quantitative information is often not available in companies and does not generally play a significant role in internal management, which is why we prefer option 2.  ESRSE1  The items subject to disclosure requirements should include: \"financial and investment planning\" (ESRS E1.14(a) amend, p. 8).  The obligation to disclose \"financial and investment planning\" would lead to an expansion of the existing disclosure requirements and increase the reporting burden. ESRS E1 currently requires \"explanation and quantification of the undertaking's investments and funding\" for the relevant measures.  ESRSS1 Own Workforce S1–7 (p.85) The proposal does not contribute to simplification but increases the reporting burden, especially for non-global companies, so it would be advisable to maintain the current requirements.  General comments Non-Mandatory Illustrative Guidance The unclear legal status of the planned NMIG document could lead to inconsistent application and unnecessary challenges with auditors, so it should not be part of the standard/delegated act."]
["Survey","ENNHRI - European Network of National Human Rights Institutions","NGO","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","As declared in response to question 17 ENNHRI is concerned with individual and joint effect of the different reliefs introduced. This includes the relief for metrics with poor data quality in particular, its extension to also cover metrics for own operations, where companies are typically well-positioned to access data of sufficient quality and/or have sufficient influence to improve data quality within a reasonable time period. As such, we support the SRB members suggestion to include a time limit on the relief incentivizing progressive improvement and temporary use of this relief."]
["Survey","ENNHRI - European Network of National Human Rights Institutions","NGO","Belgium","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","Methodology for calculation of non-EU adequate wages is ENNHRI's biggest technical and substantive objection to amended Social standards . As national human rights institutions, ENNHRI's members are critically aware of the challenges for the millions of workers living in poverty notably because of the failure of wages, including in many jurisdictions statutory minimum wages, to constitute adequate or living wages. Workers in and outside EU have a human right to a living wage, meaning sufficient remuneration to support themselves and their families in a life of basic dignity.  The draft introduces unequal treatment of workers within and outside EU, disadvantaging non-EU workers by directing companies to compare wages paid with legal minimum wages aligned with the ILO's wage-setting principles and only when there are no legal minimum wages which apply a living wage benchmark. There are two main issues with the suggested non-EU methodology: o\tit incentivises use of legal minimum wage, oftentimes much lower than an adequate wage o\tit puts the task on each company to assess whether a certain wage in a certain country is adequate or not  The ILO Wage setting principles quoted in AR 22 are not the right reference point, given they focus on the process of setting wages, rather than on the result of whether the wage is adequate or not. The latter is at the heart of the objective of S1-9. Instead, the drafting should refer to the ILO Principles for Estimating a Living Wage as the relevant benchmark for both statutory minimum wages or any other living wage estimates. In addition, the drafting should put the onus on the public authorities or the living wage data providers to provide evidence on alignment with the ILO Principles for Estimating a Living Wage rather than leave this as a burden on individual companies."]
["Survey","ENNHRI - European Network of National Human Rights Institutions","NGO","Belgium","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Arup","Consultant (including software vendor)","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","2.\tWe support the simplified standards aligning with core elements of TNFD and encourage EFRAG to continue striving to maintain alignment with other international standards and frameworks, including ISSB and GRI. Improving the interoperability between the requirements in ESRS and the ISSB Standards, to enable companies to use the ISSB Standards as a starting point and 'top up' with specific impact disclosures to achieve compliance with the CSRD/ESRS, is important. We recommend explicit cross-references to TNFD LEAP and SBTN guidance, and that transition plans, offsets and targets have consistent definitions, assurance expectations and value-chain scope."]
["Survey","ENGIE","Preparer (non-financial preparing a sustainability report)","France","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","The clarifications concerning the possibility to include executive summaries, to use appendices and the stronger link established with the overall corporate reporting are very much welcome enhancements that will improve the quality and the conciseness of the sustainability statement.   The option to include non-material information, if presented clearly, is also a good step to maintain continuity for stakeholders without engaging in complex and lengthy discussions with auditors."]
["Survey","ENGIE","Preparer (non-financial preparing a sustainability report)","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","We welcome EFRAG's ongoing efforts to align the ESRS with the ISSB standards (IFRS S1 and S2). Strong interoperability is essential to ensure that sustainability disclosures prepared under the CSRD can also meet global investors' expectations and avoid the duplication of reporting efforts.  In our view, the current Exposure Draft represents clear progress. The terminology and architecture are now closer to IFRS S1/S2 and many data points in ESRS E1 either mirror or reference the corresponding requirements in IFRS S2. This facilitates \"single set of data / multiple lenses\" reporting.  Nevertheless, we see room for additional improvements:  1) Ensuring that all climate-related financial disclosure elements in IFRS S2 (e.g. financed emissions, use of carbon credits, resilience analysis) are clearly cross-referenced in ESRS E1 or, where appropriate, explicitly scoped out to avoid interpretative gaps. 2) Providing an interoperability mapping (in an appendix or as on online tool) that shows, datapoint by datapoint, how ESRS requirements correspond to IFRS S1/S2. 3) Where the ESRS include EU-specific concepts (e.g. double materiality, EU Taxonomy links), clarify how these complement rather than contradict ISSB disclosures. 4) Promote a \"building-block\" reporting approach, allowing undertakings to prepare a single set of disclosures that can be used for both CSRD and ISSB purposes, with only limited additional  work required for EU-specific needs.  Finally, we encourage EFRAG and the ISSB to maintain an ongoing dialogue and synchronize future amendments, so that, once implementation has started, preparers do not face diverging requirements."]
["Survey","ENGIE","Preparer (non-financial preparing a sustainability report)","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","This application requirement is essential for a better understanding and should be aligned with the target setting."]
["Survey","ENGIE","Preparer (non-financial preparing a sustainability report)","France","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Overall, the changes introduced in ESRS E2 are editorial and structural changes that enhance the standard's conciseness and clarity. We however consider the introduction of new quantitative datapoints, especially for complex information such as primary and secondary microplastics, to have failed to deliver the expected simplification and this should be removed."]
["Survey","ENGIE","Preparer (non-financial preparing a sustainability report)","France","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Despite the useful simplification elements, we consider that the standard ESRS G1 should be improved by : -\tDeleting new requirements related to procurement team training on business conduct (G1-2) -\tDeleting requirements related to the number and nature of confirmed incidents of corruption and bribery -\tDeleting quantitative metrics on payment practices as this is too complex to collect for international groups with thousands of suppliers and operating in dozens of countries."]
["Survey","Deutsches Aktieninstitut","Business association (other than association of financial institution)","Germany","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We consider the proposed relief to be a practical and necessary addition. It acknowledges the real-world limitations that many preparers face, especially in complex areas such as value chain reporting. The relief helps companies improve their data collection processes and quality, before reporting metrics externally. It ensures that data collected for reporting purposes is reliable and robust. Forcing the collection of weak data does not contribute to high-quality reporting or comparability. It also increases the risk of legal issues related to the disclosure of unreliable metrics and may lead to a distorted or misleading representation of actual information.  It is also important to note that many Wave 1 undertakings will benefit only to a limited extent from this relief. In many cases, data collection approaches – often based on workarounds – have already been agreed upon with auditors and implemented. Continuing with these established methodologies may require less effort than reassessing and justifying the application of the new relief."]
["Survey","Deutsches Aktieninstitut","Business association (other than association of financial institution)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","We welcome the improved organization and consolidation of the ESRS requirements. The changes made may reduce the effort required for data collection, documentation, and coordination with auditors.  However, many changes seem cosmetic without altering the underlying substance of the disclosure requirements. We do not anticipate a significantly reduced reporting volume under the amended ESRS, as the scope and complexity of the disclosures remain largely unchanged.  Major concerns remain:  •\tRegarding newly introduced concepts and methodologies that may increase the reporting effort.  •\tThe simplification and reduction of datapoints have also been accomplished by merging, rephrasing, and restructuring many disclosure requirements and datapoints. This represents significant additional effort for Wave 1 undertakings as each change requires a re-assessment of already conducted standard interpretation. It also led to unclear and primarily descriptive paragraphs, such as ESRS 1 paragraph 27 and AR 20 related to paragraph 49, on assessing the undertakings' materiality.  •\tWe expect an increase in effort related to the new datapoints e.g. of E5 as well as through the changes in S1. •\tExpressions like \"is useful information\" (e.g., ESRS 2, AR 32) or \"is a possible aspect to cover\" (e.g., AR 33) continue to appear. These formulations may lead to uncertainty regarding the actual requirements for undertakings.  We call for fewer mandatory indicators but that are clearly defined by the ESRS for everyone.  Please delete:  •\tAnticipated financial effects (in ESRS 2 & E1), reduction in reporting on the DMA (IRO-1) •\tData points that aim to describe the \"how\" (e.g. ED ESRS 2. AR4, ED ESRS 2.25, ED ESRS 2.26, ED ESRS E1.AR5 und AR6, ED ESRS E1.18)  •\tAll new requirements, such as S1 breakdowns due to the changed country breakdowns. Further examples can be found in the Log of Amendments in column 3, marked as \"NEW.\""]
["Survey","Deutsches Aktieninstitut","Business association (other than association of financial institution)","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","AR 26 is a special feature of E4. It is presented as a separate AR (26) due to the significant number and diversity of biodiversity drivers, including land use, pollution, invasive species and climate. In other standards the corresponding requirements are integrated, often within the AR of the relevant disclosure requirements for metrics and targets (E1, E5, S1 and S2). The basic requirement is to present the methodology and data sources in a way that makes the information traceable, verifiable and comparable. Due to the intended simplification, we would recommend that the same requirements apply to E4 as to the other topical standards, rather than there being any specific requirements for E4.  For financial institutions, biodiversity targets are rather connected to portfolio alignment, sector inclusion, engagement targets, or impact reduction based on metrics disclosed by investees, emphasizing the shift of capital flows rather than direct operational control. Therefore, any guidance included in a revised AR 26 on target setting will struggle to capture the diverse requirements across sectors. Given this disparity, we suggest not including specific target guidance in the ESRS, allowing flexibility for each sector to define targets that are relevant to their unique roles and impacts on biodiversity and ecosystems. If guidance should be provided, we suggest including guidance in setting biodiversity- and ecosystems-related targets in the non-mandatory implementation guidance (NMIG)."]
["Survey","Deutsches Aktieninstitut","Business association (other than association of financial institution)","Germany","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","In E2-5, the emphasis on manufacturers and importers over users is noticeable. This is the only place where a distinction has been made beyond the real economy and the financial economy. Supplementing REACH only in relation to \"articles\" could lead to additional hurdles for manufacturers."]
["Survey","Fundación ONCE ","NGO","Spain","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Fundación ONCE ","NGO","Spain","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Fundación ONCE ","NGO","Spain","35.S1-4."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","For the new ESRS S1-4 (formerly S1-5), the omission of Appendix A.4: Application Requirements for ESRS S1–5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities results in the loss of key illustrative examples that supported companies in setting meaningful, concrete targets related to disability inclusion. In particular, this appendix listed examples under Social and human rights matters, such as \"increasing the % of persons with disabilities in own workforce\" and \"increasing the % of underrepresented groups in own workforce and top management.\" These examples provided useful guidance for preparers on how to align their target-setting with the principles of inclusion and non-discrimination. Although this appendix did not impose mandatory requirements, its removal reduces clarity and risks weakening companies' accountability on disability-related targets. Reintroducing such examples in the updated corresponding AR would be fully compatible with the simplification approach while preserving visibility for disability issues in the ESRS framework. Alternatively, introducing these mentions as examples in the respective NMIG would ensure a minimum level of visibility of persons with disabilities in the targets related to companies IROs.","S1","Disclosure Requirement S1-4 - Targets related to Own Workforce",""]
["Survey","Community of European Railway and Infrastructure Companies (CER)","Business association (other than association of financial institution)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","In general, we welcome these simplifications, particularly the streamlined terminology – now using only the term \"topic\". However, the structure involving sub-topics is still pending clarification. The changes insist on the importance of the double materiality analysis, a cornerstone of the CSRD, and simplify both its implementation and the description of the adopted process. Overall, the requirement has indeed become simpler, both in terms of wording and in terms of the interpretation of dual materiality. In our opinion, it will be easier for companies to identify material information. While avoiding excessive detail is an understandable and important goal, excessive flexibility may lead to issues with transparency, comparability, reliability, and inconsistency."]
["Survey","Community of European Railway and Infrastructure Companies (CER)","Business association (other than association of financial institution)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Community of European Railway and Infrastructure Companies (CER)","Business association (other than association of financial institution)","Belgium","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","When it comes to employee turnover (S1-5-23c), we would prefer an option to use total headcount (end of year) as denominator instead of average headcount. We argue that since most of other disclosure requirements don't require to use of average, but the company can choose to use total et the end of the year or FTE instead, this requirement should have the same option.  This new information on \"ten largest countries\" should be removed because it adds a specific granularity that may not be relevant."]
["Survey","Swedish Corporate Reporting Board","(National) standard setter","Sweden","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","The proposed amendments make the standards easier to understand and more accessible for readers with less prior knowledge of the reporting framework."]
["Survey","Swedish Corporate Reporting Board","(National) standard setter","Sweden","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree","We find it important that the ESRS standards consider the specific requirements of the EU regulatory environment and the disclosure requirements of Sustainable Finance Initiatives. We find this approach to support the objectives of the Green Deal and therefore it is acceptable to maintain these disclosure requirements that are needed by the users while still meeting the objective of simplification at the more overall level.",null,null,""]
["Survey","Swedish Corporate Reporting Board","(National) standard setter","Sweden","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","N/A, see above"]
["Survey","Swedish Corporate Reporting Board","(National) standard setter","Sweden","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","We agree that the suggested changes would in most cases lower the reporting burden."]
["Survey","Swedish Corporate Reporting Board","(National) standard setter","Sweden","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","We agree with the amendments suggested and believe that the changes are sufficient and do not reduce the objectives in respect to SMEs compared to the former phrasing."]
["Survey","Swedish Corporate Reporting Board","(National) standard setter","Sweden","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","Based on the same arguments as in question 22 above."]
["Survey","GLOBAL CSR","Consultant (including software vendor)","Denmark","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Misleading. It is very arbitrary, what has triggered the proposal of data points."]
["Survey","GLOBAL CSR","Consultant (including software vendor)","Denmark","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree"]
["Survey","GLOBAL CSR","Consultant (including software vendor)","Denmark","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree"]
["Survey","GLOBAL CSR","Consultant (including software vendor)","Denmark","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","GLOBAL CSR","Consultant (including software vendor)","Denmark","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Global Network Initiative (GNI)","NGO","United States","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Business & Science Poland (BSP)","Business association (other than association of financial institution)","Poland","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We fully back the relief measures as regards the use of reasonable and supportable information that is available without undue cost or effort as it will significantly reduce the administrative burden on reporting undertakings. We believe this provision should be permanent and not subject to a time limit as proposed by some EFRAG SRB members as mentioned in paragraph 76 of the [DRAFT] Basis for Conclusions. In the case of large Capital Groups, some information may not be available for a long time, not just a year or two, due to the fact it requires a complete remodeling of the current method of data collection.  We support ESRS 1, paragraph 92, which acknowledges the practical limitations of data availability in joint operations where the undertaking lacks operational control. Allowing the exclusion of such operations from environmental metrics is a pragmatic solution that enhances reporting feasibility and avoids duplicative or misleading disclosures.  Similarly, we endorse ESRS 1, paragraph 91, which permits the use of metrics based on a partial scope of calculation. This flexibility is vital in the early years of reporting, when data systems are still evolving. Importantly, the requirement for companies to disclose the scope limitations and outline plans to improve data coverage ensures transparency and demonstrates continuous progress."]
["Survey","Business & Science Poland (BSP)","Business association (other than association of financial institution)","Poland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","We would like to support the wording included in OPTION 2, since it addresses our concerns on the sensitivity of the information disclosed and the excessive burden on calculating quantitative disclosures. The issue of anticipated financial impacts is extremely difficult. Advisors themselves do not yet know how to approach the topic and preparing the input for the disclosure of such data can take years for large capital groups. In addition, such flexibility is required given the significant legal risks which are particularly acute where disclosures include financial data not reported in official financial statements and not reliably estimable. Such disclosures should fall under the remit of financial boards to ensure consistency with financial reporting requirements. If disclosure requirements are maintained, they should focus on qualitative information only, providing general indications of the time horizon and type of effects (e.g., financial position, performance, cash flows). Anticipated effects must be consistent with those considered for the current financial effects. Crucially, inherent effects should not be required, as these are theoretical, not grounded in reasonable and supportable information, and risk misleading external users."]
["Survey","Business & Science Poland (BSP)","Business association (other than association of financial institution)","Poland","22.G1","Comments on deleted datapoints in ESRS G1","I agree","We endorse the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","Business & Science Poland (BSP)","Business association (other than association of financial institution)","Poland","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We strongly agree with the objective of simplification in DR E4-4. When it comes to biodiversity and other nature-related issues, the central difficulty lies in the lack of standardized, well-defined, and comparable indicators. Unlike climate reporting, which benefits from the broadly recognized metric of CO₂ equivalents, this area remains fragmented, creating a high risk of inconsistency across disclosures.  Moreover, the LEAP assessment process identified in the ESRS as the foundation for biodiversity transition planning is extremely demanding. For large companies, such an exercise may require 6–9 months to complete, involve considerable financial and human resources, and still produce results of limited comparability and questionable usefulness for decision-making."]
["Survey","Business & Science Poland (BSP)","Business association (other than association of financial institution)","Poland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","Current indicator does not make distinction between positions held by employees, neither taking into account purchasing power between markets, or other important socio-economic and macroeconomic factors that strongly feed into ultimate discrepancy in income between genders, not to mention matters associated with outcome differences that are based on personal choices and personality traits. Studies, including  Harvard University \"Why Do Women earn Less Than Men? Evidence from Bus and Train Operators\" by Valentin Bolotnyy and Natalia Emanuel (2018), show that while there is inherent bias with regards to sexes, it is of no explicative utility in any statistically significant manner. Variable of highest explanatory power for differences in pay between males and females is different choices with regards to overtime and propensity to ask for raises – both levels of which vary greatly between males and females.  Given the complexity of adjudicating what gender pay gap actually means, process of collecting said data is not meaningful, and certainly should not have any a priori bearing on the classification of whether a company rates highly in an ESG context, or for the needs of CSRD reporting. We propose that the indicator is removed or modified in a way that would make it meaningful from a disclosures perspective, for ex. by weighing the gender pay gap by overtime differences between sexes, so that it is properly contextualized. We recommend that [DRAFT] DR S1-15 paragraph 44(a) be based on comparable employee profiles and reformulated as \"gender pay gap by employee category.\" Regarding [DRAFT] DR S1-15 paragraph 44(b), standard should either permit disclosure limited to an adjusted ratio, or adopt the earlier EFRAG approach of \"countries with a significant number of employees.\" Another workable option would be to require disclosure for five largest countries in which a company operates, following model used in current S1-8."]
["Survey","Bundesverband Nachhaltige Wirtschaft e.V.","Business association (other than association of financial institution)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","EFRAG is reducing the number of mandatory disclosures by over 56% and eliminating all voluntary disclosures. This significantly reduces the amount of information contained in the binding framework. These reductions affect all qualitative content relating to environmental, social, and governance issues. Although much of the content has been moved to the Non-Mandatory Illustrative Guidance (NMIG), it is no longer legally binding there. This carries the risk that key information for comparability and verifiability will be lost. This counteracts the goal of transparency through sustainability reporting. The BNW therefore calls for essential data points, especially those relating to climate impact, to remain mandatory. In addition, information that is crucial for regulatory connectivity—for example, in relation to the SFDR or the EU taxonomy—must remain mandatory in the mandatory standard section.  Clear labeling of content moved from the NMIG  The transfer of numerous content-relevant requirements from the binding ESRS standards to the Non-Mandatory Illustrative Guidance (NMIG) has led to increased confusion. For companies, auditors, and other stakeholders, it is not clear which content is still relevant and which serves only as supplementary guidance. We therefore call for all content transferred to the NMIG to be clearly and transparently labeled – both in the standard text and in the NMIG itself. This applies in particular to content from ESRS E4 (biodiversity), ESRS S1 (social) and ESRS G1 (governance). This labeling must clearly indicate which requirements were originally part of the binding standards and which are now considered illustrative guidance. Only through such transparency can the traceability of reporting and consistency in the application of the ESRS be ensured."]
["Survey","Foundation for Family Businesses and Politics ","Business association (other than association of financial institution)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Foundation for Family Businesses and Politics ","Business association (other than association of financial institution)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Foundation for Family Businesses and Politics ","Business association (other than association of financial institution)","Germany","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","Some family businesses propose a renewed review of whether the changes actually bring relief and clarity."]
["Survey","Foundation for Family Businesses and Politics ","Business association (other than association of financial institution)","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Foundation for Family Businesses and Politics ","Business association (other than association of financial institution)","Germany","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","ESG Book GmBH","User (analyst, data provider, rating agency, etc.)","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Overall, we welcome the furthering of interoperability as this strikes the right balance between improving alignment and meeting the simplification objectives. Where possible, regulators and standard-setters should continue collaboration, with the fair presentation framework as the basis and the general filter for materiality ensuring that methodology remains in line with the IFRS S1 financial materiality lens.  We also welcome the removal of one of the main interoperability differences, with the ESRS E1 GHG emission boundary now aligned to the financial consolidation approach (ESRS E1 AR19) and consistent with the financial control approach in the GHG Protocol. A separate disclosure based on operational control is only required for entities with more complex ownership structures (ESRS E1 AR20), which is proportionate and aligns with the GHG Protocol.  We note positively that the IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of those still pending outcome of Level 1 discussions (commercial sensitivity of opportunities, Scope 3 impracticability, omission of financial effects where skills are lacking). However, we caution that implementing additional reliefs beyond IFRS S1 and S2 risks creating new interoperability differences.  We strongly support the permanent reference to SASB Standards and IFRS industry-based guidance for entity-specific sector disclosures until ESRS sector standards are issued. This ensures continuity, comparability, and usability for preparers and users. Advancement of interoperability in the Basis for Conclusions is also supported.  On aligned datapoints, we agree with the deletion of overlapping requirements where equivalent disclosures remain elsewhere in ESRS, thereby reducing redundancy. However, the deletion of certain IFRS-aligned datapoints (e.g., gross GHG intensity, governance integration, remuneration linkages) risks undermining comparability. We recommend retaining such datapoints in NMIG or ARs as voluntary disclosures to avoid unnecessary divergence."]
["Survey","ESG Book GmBH","User (analyst, data provider, rating agency, etc.)","United Kingdom","22.S2","Comments on deleted datapoints in ESRS S2","I agree","We support this simplification, as respondents have already provided input on the appropriate granularity of social information in SFDR PAIs, so consolidation may be a necessary step. These disclosures could potentially be phased out or refined as the SFDR framework is finalized, particularly for metrics related to human rights and the company's own workforce, which are difficult to consolidate across the value chain and in complex operations. Narrative disclosures should supplement these metrics where the information is material.  The amendments significantly simplify the standards through a principle-based approach, reducing ESRS S1 by one DR and ESRS S2–S4 to four DRs each. Human rights policy disclosures are now centralized in ESRS 2 GDR-P, rather than being repeated in the social standards (S1–S4 DR1). In addition, previous DRs 2 and 3, which related to stakeholder engagement, channels to raise concerns/grievance mechanisms, and approach to remedy, have been merged into a single disclosure. This simplification improves usability, reduces duplication, and allows preparers to focus on material social topics while maintaining transparency."]
["Survey","ESG Book GmBH","User (analyst, data provider, rating agency, etc.)","United Kingdom","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","While shifting to the \"top 10 largest countries by headcount\" improves comparability across undertakings, it may increase reporting burden for companies with geographically dispersed but relatively small operations. A hybrid approach (e.g., limiting the requirement to top 5 countries unless they exceed a materiality threshold of total workforce) could strike a better balance. For large multinational groups with operations in many countries, disaggregating to 10 countries may mean pulling more granular data than is actually decision-useful for users. It also risks shifting focus away from countries where social risks are higher (e.g., low union coverage, weak labour protections), since it is purely based on headcount size."]
["Survey","ESG Book GmBH","User (analyst, data provider, rating agency, etc.)","United Kingdom","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome alignment with the GHG Protocol and the financial consolidation boundary for emissions, with operational control disclosures only for complex ownership structures. Optional splits for financial institutions and simplified anticipated financial effects disclosures reduce burden. IFRS reliefs for undue cost, ranges, and quantitative effects improve usability. Additional reliefs beyond IFRS may create minor interoperability differences, which require continued coordination with the ISSB."]
["Survey","ESG Book GmBH","User (analyst, data provider, rating agency, etc.)","United Kingdom","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","same as comments for ESRS S2"]
["Survey","Cefic - The European Chemical Industry Council","Business association (other than association of financial institution)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We believe the changes proposed will provide reporting undertakings more flexibility in the preparation of their sustainability statements and will allow them to focus and highlight the more relevant information. It is relevant the option to disclose the most granular information or EU Taxonomy-related information in dedicated sections or appendices, as specified in [DRAFT] ESRS 1 section 8.2, and the option of including an executive summary.  However, we recommend removing or relocating (amended) ESRS 1, AR 36. This Application Requirement suggests that undertakings may present detailed GHG emission calculations in a separate appendix or section. As this is not a mandatory requirement and is specifically related to ESRS E1, its inclusion in ESRS 1 may cause confusion. We recommend either removing it or relocating it to ESRS E1 (Climate Change), in which context it would be more appropriate"]
["Survey","Cefic - The European Chemical Industry Council","Business association (other than association of financial institution)","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We fully support the relief measures as regards the use of reasonable and supportable information that is available without undue cost or effort as it will significantly reduce the administrative burden on reporting undertakings. We believe this provision should be permanent and not subject to a time limit as proposed by some EFRAG SRB members (as mentioned in paragraph 76 of the [DRAFT] Basis for Conclusions.  We strongly support the provisions outlined in ESRS 1 paragraph 92, which recognize the practical limitations of data availability in joint operations where the undertaking lacks operational control. Allowing the exclusion of such operations from the scope of environmental metric calculations is a pragmatic and necessary relief that enhances the feasibility and integrity of sustainability reporting and avoids duplicative reporting.  In addition, we endorse the flexibility provided under ESRS 1 paragraph 91, which permits the use of metrics based on a partial scope of calculation. This approach acknowledges the evolving nature of data systems and reporting capabilities. Crucially, it encourages transparency by requiring undertakings to disclose the limitations of their current data coverage and to outline concrete actions aimed at improving completeness in future reporting periods."]
["Survey","Cefic - The European Chemical Industry Council","Business association (other than association of financial institution)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","The introduction of the concept of \"fair presentation\" raises significant concerns. We understand that the notion of \"fair presentation\" would increase alignment with ISSB standards and help reporting undertakings to further clarify the expectations related to analysing entity-specific material IROs.  However, we agree with some EFRAG SRB members that it can lead to additional obligations for companies, as they would not only need to comply with the standards but also be required to demonstrate that the information reported is a fair representation with respect to all relevant stakeholders. At the same time, this could also potentially increase Boards members' responsibilities and auditor costs.  The ESRS introduce impact materiality, encompassing environmental and social dimensions beyond financial relevance. Applying a fair presentation standard in this context risks disproportionate legal, assurance, and reputational exposure for preparers.  Sustainability data is often forward-looking, qualitative, and judgement-based, lacking the evidentiary rigor of financial data. The absence of established practices and experience for impact materiality makes it difficult to define what constitutes a \"complete and faithful\" representation, increasing uncertainty and inconsistency.  We therefore recommend EFRAG to thoroughly assess the implications of implementing the concept of \"fair presentation\" in sustainability reporting."]
["Survey","Cefic - The European Chemical Industry Council","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","While we agree with the deletion of that voluntary datapoint, in [DRAFT] DR S1-15 it is impossible to apply hourly pay since some work contracts rely specifically on there being no working hours (annual working days). Creating a methodology to approach hourly pay would defeat the purpose of this kind of contract and couldn't represent accurately the hourly pay of such workers. In addition, disclosing only one gender pay gap disadvantages disproportionately groups that have companies in emerging countries, as the pay in such countries will be compared to those of developed countries.  As regards [DRAFT] DR S1-15 44(b), the indicators are too global and not relevant, difficult to prepare and again, will disproportionately discriminate global groups. In addition, a consequent amount of the top management's remuneration relies on variable income, which in turn relies on the financial results and statements; this indicator cannot therefore be calculated accurately before the certification of the financial statement.  The preparation of these disclosures is significantly challenging for large multinational groups with numerous subsidiaries. This would require having data on the annual salary of each employee of the group, which would have to be collected outside the HR and payroll system. Obtaining such data would be also difficult in the context of the EU data protection law, as it is only available to the employer at subsidiary level.  We reiterate that [DRAFT] DR S1-15 paragraph 44(a) should be calculated on the basis of comparable profiles (e.g. \"Gender pay gap by employee category\"). [DRAFT] DR S1-15 44(b) should give the possibility to present only an adjusted ratio or to use the concept defined previously by the EFRAG of \"countries with a significant number of employees\" and disclose the ratio of such countries, or the 5 biggest countries of the company (e.g. current S1-8)."]
["Survey","PensionsEurope","Association of financial institutions","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We do not support the removal of the requirement to disclose whether a Policy, Action, or Target (PAT) or timelines have been removed for material topics. Transparency is essential, particularly for material negative impacts and risks. Therefore, choosing to remove PATs should require an explanation. Without an explanation, companies may simply state \"no PAT\" without clarifying existing gaps or intended actions, weakening accountability and comparability for investors. We also have concerns about the reformulation of certain mandatory datapoints into Application Requirements (ARs). The legal status of ARs may be unclear to preparers, potentially leading to inconsistent interpretation and reduced enforceability. Clear communication that ARs represent mandatory methodological guidance is essential to maintain consistency and reliability in reporting. Finally, we support the restructuring of the reporting architecture, which promotes conciseness and reduces duplication. It is important that companies focus on reporting what is most material to their operations, while maintaining clarity and completeness for users of sustainability information."]
["Survey","PensionsEurope","Association of financial institutions","Belgium","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","We welcome the increased interoperability between ESRS and IFRS S1/S2 (both in wording and the reliefs)  We support maximum interoperability, provided it does not compromise the ESRS's double materiality principle. Most asset owners (pension funds) require both the financial dimension offered by IFRS S1/S2 and the broader impact dimension of ESRS.  Key considerations: ESRS E1 must remain broader than IFRS S2, covering both impact and risk dimensions, including target alignment, transition CAPEX, and forward-looking metrics. The true value for investors lies in linking sustainability impacts to financial statements, not merely harmonizing terminology."]
["Survey","PensionsEurope","Association of financial institutions","Belgium","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","We recommend greater transparency for the procurement practices of large undertakings, as these can significantly influence value chain impacts.  For example, strict contractual terms (such as tight delivery deadlines) may unintentionally contribute to adverse labour conditions, including excessive overtime. Improved transparency in how suppliers are managed would help investors better assess social risks and the effectiveness of a company's due diligence processes."]
["Survey","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","Despite significant reductions in \"shall\" datapoints, EFRAG achieved to preserve the key requirements that keep the core of the ESRS intact. However, for the environmental reporting standards, we note that a further reduction would likely impair their overall usefulness."]
["Survey","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Please see our detailed feedback on ESRS 1 and 2, ESRS E1, E2, E3, E4 and E5 in the excel sheet submitted in part 3 of this survey and in our feedback paper."]
["Survey","Baker Hughes","Preparer (non-financial preparing a sustainability report)","United States","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","While the wording may be simplified, the revised definition of materiality fails to simplify the DMA or clarify materiality determinations. The definition of materiality in Paragraph 21 should derive from the undertaking's determination of what is \"material\" to the users of its financial and sustainability statements. It should enable undertakings to define  materiality based on its unique situation. An acceptable standard for financial materiality would be the standard set out in the relevant financial reporting regulation or as determined by undertaking's corporate enterprise risk programs, which serve to identify and manage significant or material risks to companies.  the value chain boundaries should be clarified and limited to the undertaking's direct business relationships. Appendix B \"Qualitative Characteristics of Information\" contains subjective guidance therefore should be classified as interpretive, not authoritative or legally binding.   It reads like a \"writers' guide\" for sustainability reports and often states the obvious, like the report should provide a \"faithful representation\" and be \"understandable.\" There is a lack of clarity around what constitutes a \"fair\" view from the users' perspective.  Such terms are very subjective and depend on the perspective of the reader, thereby presenting potential challenges in terms of exercising judgement on what is needed to fulfil the requirement. Especially given that sustainability reporting (and the concept of impact materiality) is less mature than financial reporting, where the concept of \"fair presentation\" is better-established.  The proposed amendments are likely to increase legal risks and audit costs. from an assurance perspective, the amendments will allow third-party auditors to expand their control and authority. This contradicts the Commission's February 2025 Omnibus proposal stating that a goal of the simplification exercise is  \"to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process.\""]
["Survey","Floridienne","Preparer (non-financial preparing a sustainability report)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Floridienne","Preparer (non-financial preparing a sustainability report)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","This kind of \"predictions' are so unaccurate that it is not worth spending time in making it."]
["Survey","Floridienne","Preparer (non-financial preparing a sustainability report)","Belgium","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Floridienne","Preparer (non-financial preparing a sustainability report)","Belgium","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Eurogroup for Animals","NGO","Belgium","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Eurogroup for Animals","NGO","Belgium","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Eurogroup for Animals","NGO","Belgium","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","DUFAS","Association of financial institutions","Netherlands","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","DUFAS supports that investee companies strike a balance between identifying and uncovering available information without undue cost or effort to conduct their assessments and report on their metrics. We emphasize the importance that companies use this as a learning curve, having to continuously improve over time.  Our concern is that repeated use of narrow scopes could weaken trend and peer comparability and complicate assurance. To preserve reliability, any reliance on reliefs should be accompanied by clear guardrails, e.g. explicit rationale for invoking the relief and the decision criteria applied, scope transparency, time-bound improvement plans, method transparency. As the Basis for Conclusion mentions, the objective is to align with the IFRS S1 reliefs, which enhances interoperability."]
["Survey","DUFAS","Association of financial institutions","Netherlands","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","DUFAS welcomes the introduction of the new mandatory datapoints, as they are relevant to investors because they make explicit the elements that are critical for assessing a company's sustainability performance and risk exposure. From an investor standpoint, these datapoints will improve comparability, transparency and decision-usefulness without introducing undue burden, given particularly their direct link to existing disclosure objectives."]
["Survey","DUFAS","Association of financial institutions","Netherlands","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","DUFAS reiterates its position that client assets should be explicitly excluded from the scope for purposes of CSRD reporting. In particular, some requirements have not been amended in the proposed revised ESRS, as they are indicated to be subject to Level 1 changes, including the value chain for FIs. Therefore, we do not interpret any changes that might indicate reference to the value chain for FI as such, including ESRS 1 paragraph 38 and ESRS 2 paragraph 68. We do welcome further clarity on the definition of FIs own operations in L1, in line with the presentation in paragraph 59 (p.42) of Log of Amendments ESRS 1 General Requirements stating that own operations relate to \"assets, liabilities, income and expenses\". EFRAG also notes that some requirements were not changed in the amended ESRS as they are subject to level 1 changes, for example regarding 'compatibility with 1.5 degrees\" for the Transition Plans disclosures. However, clarification is needed, for example regarding the base year (reference point) for measuring the reduction of greenhouse gas emissions and setting climate targets. Guidance on the comparability between disclosures, where the implementation year among different companies differs, as the CO2 data improves over time, would be helpful and would establish an accepted way of working for external auditors to ensure reliable information.  By way of guidance, we propose EFRAG to develop a standard model report that includes the minimum reporting requirements per ESRS, such as a structure, table of contents with tables and/or graphs, and explanatory notes. For financial accountability reports, including annual accounts, the use of standard model reports has been common practice for years. Applying a similar approach to sustainability reporting based on ESRS would provide clarity for both preparers and auditors regarding what and how information should be reported."]
["Survey","CDP","Standard setting initiative","United Kingdom","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","CDP welcomes amendments that remove duplication and encourage an integrated approach to PATs. These changes reduce overlap with MDR and topical standards, ease reporting burdens, and simplify application of the ESRS digital taxonomy.      While the principle-based approach to PAT disclosures provides flexibility to companies, the granular requirements provided valuable guidance. Linking the standard to the relevant NMIGs - or embedding them in topical standards, would help ensure the necessary level of detail and topic specificity for meaningful reporting.      CDP flags the following areas as potential risks to ambition and/or obscure material information:      The requirement to disclose whether an undertaking plans to implement a PAT for material topics, and the associated timeline, should be retained.   This data is critical to assess whether companies are moving from commitments to implementation. These will allow companies to disclose their progress to come, not just past actions. Retaining this disclosure requirement will be key to encourage transparency, accountability and drive meaningful action through disclosure requirements.   Elimination of detailed information required if the organization determines that climate change is not material (ESRS2, 28b)- though the extent and nature of climate impacts vary by sector, it would be important for companies to explain the rationale behind omitting climate related disclosures including how this was assessed as part of their materiality assessment and potential of climate change being a material topic in the future."]
["Survey","CDP","Standard setting initiative","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","CDP supports the transition of the aforementioned data points from voluntary to mandatory reporting, particularly those that capture key details enabling stakeholders to understand water balance and the transition plans for biodiversity and ecosystems.   However, limiting the disclosure of nature transition plans to cases where they are already publicly available undermines the principle of double materiality and the ESRS's broader focus on material impacts, risks, and dependencies. We support elevating the requirement to a \"shall\" but recommend that it apply to companies or sectors with significant nature-related risks and dependencies, rather than being contingent on prior public disclosure.    Broadening the requirement for nature transition plans to all companies for whom it is material could avoid addition of significant extra burden due to the fact that nature transition plans are currently not as detailed as climate transition plans  but also could be integrated into climate transition plans. Movement towards integrated transition planning is already happening in voluntary reporting."]
["Survey","CDP","Standard setting initiative","United Kingdom","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","It is vitally important for principle of double materiality to be maintained in order for the information reported to be meaningful for users. As mentioned in other responses the driving principles guiding these amendments should be the enhancement of ambition and comparability while reducing burden."]
["Survey","Assogestioni","Association of financial institutions","Italy","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Assogestioni acknowledges EFRAG's intention to streamline the ESRS architecture. We view ESRS 2 (General Disclosure Requirements) as a safeguard against materiality-driven omissions, ensuring that cross-cutting governance, strategy, and impact-related information remains available even when topical standards are deemed non-material. The preservation of \"shall disclose\" General Disclosure Requirements is therefore a positive step. Nonetheless, we do not support the elimination of the requirement to disclose whether undertakings plan to implement Policies, Actions, and Targets (PAT) for material topics and associated timelines. Removing this obligation risks obscuring how companies intend to address identified sustainability risks and opportunities. Transparency requires explanation when PAT are absent—particularly for material negative impacts and risks—otherwise investors may face weaker comparability across undertakings. Without this, companies could simply declare \"no PAT\" at the topic level without clarifying where strategic gaps exist or how they will be addressed. From an asset management perspective, this information is critical. Eliminating mandatory transparency on PAT plans diminishes the ability to assess transition readiness, net-zero alignment, and progress monitoring, which are key inputs for stewardship and investment decision-making. We recommend retaining a minimum layer of PAT transparency across all material topics, irrespective of whether implementation has started. Alternatively, an \"explain if not\" requirement would ensure that the absence of PAT reflects a deliberate strategic choice rather than an omission, thereby safeguarding comparability, accountability, and investor confidence."]
["Survey","Assogestioni","Association of financial institutions","Italy","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Assogestioni welcomes the amendments introduced to strengthen interoperability with international standards. We support the inclusion of IFRS reliefs and the use of aligned language, as these measures help ensure consistency for preparers reporting under both ESRS and IFRS frameworks. Interoperability must be maximised without diluting the principle of double materiality, which remains a defining strength of ESRS. We particularly value EFRAG's proposal to reference IFRS industry-based guidance and SASB standards as sources for entity-specific sector disclosures. This is a practical and user-friendly step that will support preparers while enhancing decision-useful information for investors. At the same time, we are concerned that some reliefs introduced in the draft exposure go beyond the ISSB framework and risk undermining interoperability. In particular, the reliefs on climate-related disclosures in ESRS E1 may place ESRS below the global baseline. This would increase the reporting burden for undertakings that must comply with both CSRD and ISSB, while reducing the quality of information available to investors. We strongly urge EFRAG to ensure closer alignment between ESRS E1 and IFRS S2, particularly on climate disclosures, to safeguard interoperability and prevent fragmentation of global sustainability reporting practices."]
["Survey","Assogestioni","Association of financial institutions","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","European Federation of Accountants and Auditors for SMEs","Auditor","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","EFAA for SMEs welcomes the provision of new guidance on how to consider remediation, mitigation, and prevention actions in the Double Materiality Assessment (DMA). This is indeed an area where clarification was needed, and the attempt to bring consistency is positive. However, we remain concerned that the approach may become disproportionately onerous for many companies, especially SMEs, and may lead to excessive reporting. The split views within the EFRAG SRB illustrate that further work is required. We would therefore advise: Pilot testing and feedback loops – Before finalising this guidance, structured pilot applications with a representative sample of companies (from several sizes) should be carried out. This would provide evidence of whether the \"gross approach\" is workable in practice and proportionate. Clearer practical examples – Appendix C is helpful, but further illustrative guidance with sector-specific examples would reduce subjectivity and increase comparability in practice. Phased introduction – A staged implementation over a few years could allow preparers, auditors, and regulators to build the necessary experience before full application. Post-implementation review – After at least three reporting cycles, the effectiveness and proportionality of this guidance should be reassessed, with adjustments made if it proves too complex or generates unnecessary reporting. In conclusion, while the guidance clarifies the principle, we believe it still requires refinement, simplification, and validation through practice to ensure that it results in relevant, comparable, and proportionate reporting."]
["Survey","European Federation of Accountants and Auditors for SMEs","Auditor","Belgium","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","EFAA for SMEs supports the proposed reduction in datapoints which will reduce the burden on companies of reporting."]
["Survey","European Federation of Accountants and Auditors for SMEs","Auditor","Belgium","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","EFAA for SMEs supports the proposed reduction in datapoints which will reduce the burden on companies of reporting."]
["Survey","European Federation of Accountants and Auditors for SMEs","Auditor","Belgium","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","EFAA for SMEs notes the additional work to be undertaken in the area and reserves judgment until results of this work are published."]
["Survey","2050 Consulting AB","Preparer (non-financial preparing a sustainability report)","Sweden","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We welcome the added flexibility (executive summary, use of appendices) and the emphasis on connected information. To ensure usability over time, when data is unavailable the Standard should require disclosure of a clear time plan: scope of missing data, interim estimation method, responsible function, and a target date for achieving full coverage. This will maintain conciseness while giving users visibility on data gaps and progress."]
["Survey","2050 Consulting AB","Preparer (non-financial preparing a sustainability report)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We support a more principles-based PAT approach but recommend a mandatory sequencing: targets before actions. This will mirror how companies work with sustainability and enable a more natural flow in the report. This gives the following headings and structure: •\tStrategy and targets •\tImpact risk and opportunity management •\tMetrics  Actions should explicitly reference the target(s) they serve, with a traceable link to KPIs, budgets, and timelines. Where no target exists for a material IRO, undertakings should explain why and provide a timeline to set one. This preserves simplification while strengthening relevance, accountability, and comparability."]
["Survey","2050 Consulting AB","Preparer (non-financial preparing a sustainability report)","Sweden","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","For financial institutions, intensity-based targets (e.g., emissions per unit of invested capital or revenues financed) provide a more meaningful and practical way of measuring progress than absolute targets. Their business models, portfolios, and exposures change rapidly, making absolute target-setting highly assumption-driven, administratively burdensome, and of limited additional value for steering real-world climate action. In these cases, climate benefits can be achieved equally well through intensity targets.  However, this exemption should not reduce transparency. Financial institutions must continue to report their absolute financed emissions (scope 3) on a regular basis, even if their forward-looking targets are intensity-based. This ensures stakeholders can assess both efficiency improvements and the total scale of impact. We also underline that absolute targets should remain required for institutions' own scope 1 and 2 emissions.  Finally, transparency on portfolio composition – such as the share of investments in fossil fuel-related sectors – is also highly relevant for understanding direction of travel and alignment with climate goals. While we recognize that this may fall under sector-specific reporting guidance, we encourage EFRAG to ensure such disclosures can be effectively integrated in the broader reporting framework."]
["Survey","2050 Consulting AB","Preparer (non-financial preparing a sustainability report)","Sweden","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","2050 Consulting AB","Preparer (non-financial preparing a sustainability report)","Sweden","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","2050 Consulting AB","Preparer (non-financial preparing a sustainability report)","Sweden","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We would like to raise a concern regarding the Commission's proposal on the value chain cap. Limiting companies' ability to obtain information from their suppliers to VSMEs risks undermining effective management of risks and opportunities. Such a restriction could ultimately hamper companies' capacity to improve their sustainability performance and, in the long run, weaken competitiveness."]
["Survey","VTT Technical Research Centre of Finland","Preparer (non-financial preparing a sustainability report)","Finland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","I disagree with the additions of point 1 and 2 above, as they are unclear and waters down the integrity of the report. It will also compromise the comparability of the reports. Also nr. 4 will have a trickle-down-effect to smaller companies. Nr. 5 might make it harder for investors to make decisions.   I object all deletions of \"negative statements\" (e.g. not having a diversity policy in S1). Negative statements force companies to transparently disclose performance."]
["Survey","VTT Technical Research Centre of Finland","Preparer (non-financial preparing a sustainability report)","Finland","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","GOV-2 §26c: This is an important and concrete disclosure on managements involvement in sustainability work and highlights a company's commitment.  GOV-4: Deleting requirement to disclose main risks identified and their mitigation strategies waters down integrity of report.  SBM-1: G- Elements of the undertaking strategy that relate to or impact sustainability matters deletion: I do not believe this information to be redundant.  SBM-2: Too many datapoints have been deleted regarding stakeholder engagement (20 a & c) These disclosures are necessary for the reader to understand how seriously the company engages with stakeholders.  SBM-3, IRO-2 and PAT commented earlier."]
["Survey","Siemens Energy AG","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We acknowledge the structural improvements introduced in the revised ESRS, particularly those aimed at enhancing readability and connectivity with broader corporate reporting. The clearer organisation of content and the introduction of executive summaries and appendices may support more effective communication with stakeholders, especially investors.  However, these enhancements primarily address presentation rather than substance. The inclusion of executive summaries and appendices, while helpful, implicitly acknowledges that the standards remain voluminous and complex. These additions do not resolve the underlying issue of excessive granularity, which continues to pose challenges for preparers in terms of documentation, internal coordination, and assurance.  The reliance on Non-Mandatory Illustrative Guidance (NMIG) further contributes to interpretive uncertainty.   While NMIG is intended to support implementation, its non-binding nature and undefined legal status may lead to inconsistent application and diverging expectations among auditors and regulators. In practice, NMIG content is often treated as de facto mandatory, which undermines the principle of proportionality and increases the compliance burden.  To ensure that the ESRS framework remains both decision-useful and operationally feasible, further simplification is needed. This includes reducing the volume of mandatory disclosures, clarifying the role of supplementary guidance, and streamlining the architecture of the standards to avoid fragmentation.  We recommend that EFRAG continue to prioritize simplification efforts that go beyond formatting and presentation. A more fundamental reduction in complexity is necessary to support consistent implementation, enhance comparability, and maintain alignment with the principles of proportionality and relevance."]
["Survey","Siemens Energy AG","Preparer (non-financial preparing a sustainability report)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We strongly support the objective of enhancing interoperability between the ESRS and ISSB standards. Greater alignment is critical to reducing duplicative reporting obligations and enabling companies—particularly those operating across multiple jurisdictions—to meet both frameworks through a streamlined and unified reporting process. Preparers have consistently highlighted the need for ESRS disclosures to be designed with ISSB compatibility in mind, especially where thematic and structural overlaps exist.  To facilitate practical implementation and minimize administrative burden, we recommend that after the final revision the ESRS/ISSB Interoperability Guidance be expanded to include a comprehensive, data point-by-data point comparison. Such a mapping would allow preparers to demonstrate compliance with IFRS S1 and S2 alongside ESRS requirements without the need to develop and reconcile separate documentation for external assurance purposes. This would significantly reduce effort, promote consistency across disclosures, and support a more proportionate and scalable application of the standards.  Furthermore, this approach would foster convergence between European and global sustainability reporting frameworks, reinforcing the credibility and usability of ESRS disclosures in international capital markets. It would also enable preparers to leverage existing internal reporting structures, thereby improving efficiency and reducing the risk of conflicting interpretations across assurance engagements."]
["Survey","Siemens Energy AG","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We acknowledge and welcome the improved structuring and consolidation of the ESRS disclosure requirements. The clearer grouping and separation of data points contribute to enhanced usability and navigability of the standards, particularly for preparers managing complex reporting processes across multiple entities and jurisdictions.  However, upon closer examination, many of the proposed changes appear to be editorial in nature and do not materially alter the substantive scope of the disclosure obligations. While the presentation of the standards has been streamlined, the underlying reporting requirements remain largely intact. As such, we do not anticipate a meaningful reduction in reporting volume or complexity under the revised ESRS. In several instances, the removal of data points affects only the format or phrasing, without relieving preparers of the obligation to collect and disclose the same underlying information.  In this context, we are particularly concerned about the introduction of new mandatory disclosure requirements within the revised drafts. These additions run counter to the stated objective of reducing complexity and administrative burden. Retaining them risks diluting the impact of the simplification effort and may inadvertently increase the workload for preparers, especially those already engaged in implementation planning. To preserve the integrity of the revision process and ensure proportionality, we recommend that these newly introduced mandatory disclosures be removed or reclassified as voluntary, pending further stakeholder consultation and methodological development."]
["Survey","Ministry of Finance of Estonia","Public authority","Estonia","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree"]
["Survey","Ministry of Finance of Estonia","Public authority","Estonia","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Ministry of Finance of Estonia","Public authority","Estonia","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","If the standard was not clear for certain users/prepares then it needs to be highlighted."]
["Survey","Ministry of Finance of Estonia","Public authority","Estonia","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Ministry of Finance of Estonia","Public authority","Estonia","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","In principle, the concept of the gross-net approach is to be welcomed.  It would be important to clarify how actions should be treated in the context of actual positive impacts. For example, under ESRS S1 Own Workforce, when an organisation identifies positive impact on own workforce it can be that there are internal policies and actions in place to increase the positive impact. If the respective policies and actions are set up with the focus on increasing its positive impact rather than on reducing its negative impact, it becomes difficult in practice to exclude these policies and actions from consideration when scoring its impact.  In the NMIG, examples that help distinguish between potential and actual impacts could be included. Examples could also be included in the AR or in the NMIG for financial institutions, illustrating how the gross-net approach should be applied in the materiality assessment."]
["Survey","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","In principle, disclosure of the expected financial effects is useful. We think that the amended Paragraphs 40, 41 and 42 of ESRS 1 have been significantly simplified. However, the required information should be made available in a stakeholder-oriented manner (e.g., in line with the needs of value chain partners, in particular banks and insurance companies, and, for capital market-oriented companies, additionally the capital market).",null,null,""]
["Survey","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","We consider the incorporation of a \"fair presentation\" useful to support our professional judgment when concluding upon our information materiality. However, implementing the \"fair presentation\" principle would need an additional process to be established. Under a pure compliance approach, auditors tend to expect a checklist-type review and sometimes reporting on information that is not decision-relevant. In pursuing the \"fair presentation\" concept within the ESRS, it should be clarified that its purpose is to streamline processes and reduce the reporting scope, rather than introducing an additional explanatory hurdle. The audit practice in this respect remains to be seen. The concept of \"fair presentation\" might be more appropriate to rename it \"faithful presentation\", which could provide more precise wording.  We caution that the interaction of entity-specific disclosures, the stakeholder-focused double materiality concept, and the unclear delineation of \"fair presentation\" risks an uncontrolled expansion of the reporting scope. This would contradict the political objective of simplification and proportionality in the ESRS and may create additional friction with auditors."]
["Survey","CLEPA","Business association (other than association of financial institution)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","Extending obligations to the entire value chain contradicts the objective of simplification, as it significantly increases reporting complexity without proportionate benefits for decision-making. The amendments do not sufficiently simplify the DMA process or reinforce the materiality filter, and the balance between simplification and robustness remains unsatisfactory. Further simplification is needed, particularly in reducing mandatory narrative and methodological disclosures and providing more practical guidance on materiality. The changes do not yet achieve an acceptable balance for preparers or regulators seeking both meaningful information and manageable compliance obligations."]
["Survey","CLEPA","Business association (other than association of financial institution)","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We support EFRAG's view that the Non-Mandatory Illustrative Guidance (NMIG) should remain outside the scope of the Delegated Act and continue to serve as a supporting document. Maintaining this status helps avoid confusion regarding its legal enforceability and allows NMIG to serve its intended role as a practical aid for implementation."]
["Survey","CLEPA","Business association (other than association of financial institution)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree"]
["Survey","CLEPA","Business association (other than association of financial institution)","Belgium","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","CLEPA","Business association (other than association of financial institution)","Belgium","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Impact France","Business association (other than association of financial institution)","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Quantitative information on anticipated financial effects is essential for assessing financial materiality and for integrating sustainability into business strategy and risk management. Option 1 maintains the expectation to provide such data while giving a targeted relief when measurement is not feasible or when uncertainty makes figures meaningless.  This compromise safeguards investors' need for decision-useful metrics and keeps the ESRS broadly aligned with IFRS S1/S2. It also preserves the incentive for companies to develop robust methodologies, which would be weakened if quantitative disclosure were left entirely voluntary under Option 2."]
["Survey","Impact France","Business association (other than association of financial institution)","France","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree"]
["Survey","Impact France","Business association (other than association of financial institution)","France","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree"]
["Survey","Impact France","Business association (other than association of financial institution)","France","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Airlines 4 Europe","Business association (other than association of financial institution)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","We disagree with the requirement to assess impacts on a gross basis and we disagree with the requirement to exclude mitigations that have been enacted. Entities do not operate their businesses on a gross basis alone nor are assessments made by reversing out actions taken already to mitigate risks. Simply put, users of reporting want to understand the risk to the business after mitigation. Reporting on a gross basis directly contradicts the new amendments with regard to aggregation and disaggregation of obscuring material information as a result of disclosing immaterial information. Where a risk or opportunity is determined to be material on a net basis, we consider the ESRS should encourage companies to detail what the gross risk or opportunity is, what mitigating actions have and are being taken, and therefore what the net result is. If the risk or opportunity is immaterial on a net basis, then no disclosure should be required, even if the gross risk or opportunity is considered material. Clarity on the magnitude of the impact and its relationship to the direct operations of the company should also be provided. Materiality should focus only on the most material and  highest-impact topics, rather than obligating companies to provide extensive reporting on issues of only moderate importance.  When assessing materiality, it should be taken into consideration the significance of an impact across the entire value chain, not just within their own operations.  The degree of materiality should be determined not only by the scale, the scope , and irremediability of the impact itself, but also by its relative importance compared to other impacts across the value chain."]
["Survey","Airlines 4 Europe","Business association (other than association of financial institution)","Belgium","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","We appreciate the further alignment with the IFRS sustainability standards S1/S2 and other internationally accepted standards, including the GHG protocol.  The concept should even go further and consider \"equivalence\".  Specifically, it is unclear as to why EFRAG considers the change to ESRS E1 GHG emissions boundary.   ISSB does not require companies to align their emissions boundary using the financial control approach, it only requires the company to disclose \"the approach it uses to determine its greenhouse gas emissions (for example, the equity share or control approach in the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004)\". As such, companies should be allowed to disclose emissions based on equity share, operational control, or financial control. We'd also like to see the removal of GHGP standard year to allow for flexibility as the GHGP is subject to change.  We encourage EFRAG to align with ISSB and allow flexibility in the choice of organizational boundary, rather than prescribing a strict financial control approach.  For many industries, including those operating in joint ventures, consortia or under long-term service arrangements, an operational control approach provides the most accurate reflection of emissions that management can directly influence and reduce.  We also support maintaining the three reliefs listed as exceptions (omitting commercially sensitive information on opportunities, omitting Scope 3 GHG emission categories when impracticable, and omitting quantitative financial effects). The new reporting burdens on companies are already sizeable and resource-intensive without needing to disclose information that is sensitive to the business or extremely difficult to procure and calculate based on business structure."]
["Survey","Airlines 4 Europe","Business association (other than association of financial institution)","Belgium","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree","Yes we support these revisions."]
["Survey","Airlines 4 Europe","Business association (other than association of financial institution)","Belgium","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Airlines 4 Europe","Business association (other than association of financial institution)","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We welcome efforts to clarify and simplify existing regulation. However, the amended text should be written in plain English, as the current draft is confusing and contradictory.  Double materiality assessments (DMAs) could be reported in a tabular format to improve readability, following practices used for TCFD disclosures. The amendments in paragraph 29 lack clarity on the frequency and depth of DMA reassessments. Prescriptive language should be introduced, such as a three-to-five-year cycle unless major structural changes occur. Guidance should also specify that previous DMA results are leveraged, focusing new assessments on changes in business operations.  We also note incompatible language between Article 34 and Appendix C. Paragraph 34 states that remediation actions taken during the reporting period shall not be considered when assessing materiality. Appendix C, however, requires reporting of potential impacts after prevention or mitigation if still material, and ongoing actions until residual impacts are managed. Under Article 34, mitigation cannot be netted from impacts; under Appendix C, it can. This contradiction creates confusion. Either further clarification is needed, or Appendix C should be removed, as it introduces unnecessary complexity and inconsistency into the DMA approach.  Clarity is also needed where the draft states an entity \"shall consider\" external standards (e.g., SASB, GHGP). Does this imply companies must prove to auditors that such standards were considered? If so, clear guidance is required on how to demonstrate compliance.  Finally, new datapoints such as E2-4, E2-5 and E5-4 are extremely burdensome for the aviation sector. We strongly recommend making these requirements qualitative, or at minimum allowing the use of estimates indefinitely."]
["Survey","Confederation of Danish Employers","Business association (other than association of financial institution)","Denmark","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We support EFRAG's view that the Non-Mandatory Illustrative Guidance (NMIG) should remain outside the scope of the Delegated Act and continue to serve as a supporting document. Maintaining this status helps avoid confusion regarding its legal enforceability and allows NMIG to serve its intended role as a practical aid for implementation."]
["Survey","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium","22.E1.","Comments on deleted datapoints in ESRS E1","I agree","n/a"]
["Survey","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium","22.S4","Comments on deleted datapoints in ESRS S4","I agree","n/a"]
["Survey","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The current application requirements offer a structured methodology by comparing the undertaking's lowest wage with relevant benchmarks. However, we suggest several improvements to enhance clarity, comparability, and practical implementation. First, while the benchmark hierarchy is helpful, the current approach relies heavily on minimum wage levels, which may not always reflect the actual needs of workers and their families. We recommend that EFRAG explicitly emphasise living wage benchmarks—aligned with ILO principles—as the preferred standard where available. Without this, there is a risk of inconsistent data quality. Secondly, AR 22 para.32 outlines a methodology for determining the lowest wage outside the EU, prioritising the statutory minimum wage where applicable. However, in many jurisdictions, statutory minimum wages are significantly lower than living wages. As a result, we question whether this hierarchy provides an appropriate basis for assessing wage adequacy outside the EU. Reconsider the proposed hierarchy and provide greater flexibility for undertakings to assess wage adequacy based on locally relevant benchmarks, including ILO principles on estimating a living wage and living wage estimates where available."]
["Survey","susform GmbH","Consultant (including software vendor)","Austria","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","*There could be a risk of inconsitancy, unclarity if the IRO and  topics reporting varies on different aggregation levels - even tough i support that there is reporting possible on sub-topic level."]
["Survey","susform GmbH","Consultant (including software vendor)","Austria","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","susform GmbH","Consultant (including software vendor)","Austria","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","The replacement improves the alignment of the topical standard by consolidating datapoints and linking them to PAT, but it does not  fully meet CSRD's explicit objective of protecting SMEs in the value chain. late payments are one of the most significant risks SMEs face in supplier relationships, often affecting their liquidity and survival. Narrative PAT disclosures can highlight policies and intentions, but they are insufficient to capture whether undertakings are actually paying SMEs on time. Re-introducing even a single SME-focused timeliness metric, e.g. the percentage of SME invoices paid within agreed terms; together with a short information on payment practices, would provide transparency and comparability for users, maintain pressure on undertakings to manage supplier relationships responsibly, and at the same time avoid the complexity of multiple overlapping datapoints."]
["Survey","Connect Europe","Business association (other than association of financial institution)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Connect Europe","Business association (other than association of financial institution)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree"]
["Survey","Connect Europe","Business association (other than association of financial institution)","Belgium","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Reduction in the number of data points mainly concerns qualitative data points, and not quantitative ones. As some data points have been regrouped under the same paragraph, there are facially fewer data points, but the same content remains to be disclosed."]
["Survey","Connect Europe","Business association (other than association of financial institution)","Belgium","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","\tESRS S1: New threshold for reporting metrics disaggregated at country level: We oppose the proposed changes to the current thresholds as we believe that it only leads to additional burden and reporting without creating value. We strongly urge EFRAG to keep the adjusted pay gap in place as it is more meaningful for stakeholder analysis than the unadjusted. existing system in place as it is practical.  \tESRS S1 DR15: Gender pay gap: We strongly urge EFRAG to keep the adjusted pay gap in place as it is more meaningful for stakeholder analysis than the unadjusted. \tE \tS1 – 17: Human rights violations in the form of non-compliance with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines  relating to own employees: The clarification of terms and definition in the Annex on what should be seen as a human rights violations within the meaning of the ESRS bear the risk of increasing the cost for collecting all relevant data as well as legal costs. In the light of the current simplification spirit, those new definition should only be applied to legally concluded proceedings."]
["Survey","Connect Europe","Business association (other than association of financial institution)","Belgium","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","S2 – Workers in the Value Chain: We welcome the simplified draft which emphasises that companies should not engage in theoretical scientific exercises to derive the DMA ('practical considerations', 'with undue cost or effort') but should derive materiality based on a 'top-down approach' from existing assessments, e.g. the exercise of due diligence. In this context, explicit reference is made to the results of supply chain due diligence obligations under EU law."]
["Survey","ANIA (Associazione Nazionale fra le Imprese Assicuratrici)","Association of financial institutions","Italy","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","ANIA fully supports the objective of burden reduction, mandated by the European Commission to EFRAG. In this respect, it is essential that the reduction of the reporting burden is foreseen as permanent and not temporary (while the use of term \"relief\" may imply a temporary measure). Therefore, we propose to delete the term \"relief\" (or to replace it) as they are permanent changes to the ESRS. Among EFRAG proposal, we welcome the introduction of the \"undue cost or effort\" principle, that should be applied in a generalized way. We regret that the relief for partial data coverage (§91) explicitly excludes ESRS E1-8 on GHG emissions (noted as E1-6 in the draft, which should be updated). For insurers and financial institutions, reliable Scope 3 data remain extremely difficult to obtain. Extending this relief to E1-8 would support realistic implementation while upholding the Green Deal's transparency objectives.  Finally, ESRS1 §74 requires sustainability reporting to match financial periods. This is unfeasible for investments, since investee data are only available after publication, inevitably creating a time lag. Therefore, we propose to include the option, where no other alternative is feasible, to report the most recent available information, accompanied by appropriate context."]
["Survey","ANIA (Associazione Nazionale fra le Imprese Assicuratrici)","Association of financial institutions","Italy","22.S2","Comments on deleted datapoints in ESRS S2","I partially agree and partially disagree","See comment above"]
["Survey","ANIA (Associazione Nazionale fra le Imprese Assicuratrici)","Association of financial institutions","Italy","22.S4","Comments on deleted datapoints in ESRS S4","I partially agree and partially disagree","See comment above"]
["Survey","DFDS","Preparer (non-financial preparing a sustainability report)","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","DFDS","Preparer (non-financial preparing a sustainability report)","Denmark","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","The unadjusted pay gap is not a very useful metric. If replacing it by the adjusted is not an option, having both is better."]
["Survey","AMF - Autorité des marchers financiers","National supervisory authority & regulator","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Overall, the AMF supports the simplification of the DMA. However, we have some reservations: -\tThe AMF supports the aggregation of IROs principle but recalls the objective of the ESRS to give \"information necessary to understand the undertaking's [IRO]\" (based on CSRD's Art.19a). In particular, IRO-2, §28(a) shall clearly require from companies to indicate –at least once, when reporting on the DMA results, if material topics are related to either positive/negative impact, risk and/or opportunity; for instance, there could be 3 columns labelled impact, risk and opportunity, and a simple \"check\" in the corresponding column(s) would be sufficient. This is to avoid cases where companies only report at topic-level in their entire statement, thereby leaving the user without any information about the actual IROs. -\tThe ESRS should specify that companies do not need to conduct DMA every year but that the DMA should be reviewed where a company's circumstances have changed (§29 ESRS 1) -\tIRO-1 datapoints could be streamlined to avoid redundancies. For instance, regrouping in one § methodological aspects: assumptions, inputs (including stakeholders' engagement), and explanations on thresholds. Guidance should better explain how companies can avoid boilerplate disclosures by disclosing data/tools used in relation to specific topics.  -\tInformation on thresholds is key but ESRS 1 §28 could be simplified by not requiring thresholds for each and every criterion (severity/likelihood), cf. part 3.  -\tThe AMF supports the overall reduction of list of topics in appendix A (previous AR 16) but does not agree with the idea of merging topics for S1 & S2 and regrouping multiple G1 subtopics under \"corporate culture\". This may reduce the length of the ESRS but does not improve useability and readability of the standards (especially when this results in additional footnotes that are difficult to read)."]
["Survey","AMF - Autorité des marchers financiers","National supervisory authority & regulator","France","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","AMF - Autorité des marchers financiers","National supervisory authority & regulator","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Why partial disagreement: We do not agree with some simplifications (ex: on the DMA, the gross/net new rule, support the undue cost or efforts but suggest to introduce a time-bound limit, reduce reporting on connectivity, etc.) and we identified need for important clarifications (ex: on fair presentation). There are also areas for further simplifications (eg. more flexibility on the presentation, on DMA §28). In particular, paragraph 28 of ESRS 1 seems to imply that materiality thresholds are to be set for each and every materiality criterion (scale, scope, likelihood, etc.) which seems disproportionate. While thresholds are key and should still be mentioned in ESRS 1 and ESRS 2, this paragraph could be simplified by deleting the first part of §28 (\"When applying the criteria set under Chapters 3.3.1 and 3.3.2\")"]
["Survey","AMF - Autorité des marchers financiers","National supervisory authority & regulator","France","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Why partial disagreement: support the inclusion of the TP but important clarification are needed (minimum content, conditions for disclosures). In addition, need to highlight the importance of the value chain in the guidance."]
["Survey","AMF - Autorité des marchers financiers","National supervisory authority & regulator","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"In the context of this consultation, the AMF conducted an in-depth study of the reporting practices of a sample of listed companies that published their first sustainability statement in 2025. This AMF's study « Corporate Sustainability reporting: the way forward » available in English will be shared with EFRAG and will be published on the AMF's website."]
["Survey","AMF - Autorité des marchers financiers","National supervisory authority & regulator","France","35.S1-4."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Paragraph 21 could be limited to the link with ESRS 2, GDR-T only. The disclosure on whether and how the undertaking engaged directly with its own workforce for the purpose of target setting and tracking performance seems overly narrative and already not necessarily published by companies.","S1","Disclosure Requirement S1-4 - Targets related to Own Workforce",""]
["Survey","Institut der Wirtschaftsprüfer in Deutschland e.V. (IDW)","Auditor","Germany","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","We welcome the principle-based clarification, which is very useful given that many remedial or preventive actions are either required by law or have long been established (e.g. filters for air pollution, measures to mitigate explosions, H&S management).  Regarding the detailed table in Appendix C, which mainly focusses on the timing of actions and the need to maintain significant ongoing actions, we suggest also considering market practice, facts and circumstances and other factors (e.g. the duration for which an impact may remain in effect). These could be further informed by the results of ongoing field tests.  Appendix C also seems to focus on an undertaking's own operations. We would welcome clarification on how it should be applied in relation to material impacts in the upstream or downstream value chain. According to para. 56 of the BC, the clarifications focus on impacts, since for risks and opportunities undertakings generally have experience from financial reporting which they can draw on. However, there is diversity in practice on this point (e.g. in Germany, there is an accounting policy choice regarding reporting in the management report before or after remedial actions). An alternative approach to adding rules in the ESRS could be to leave the interpretation to the ISSB/TIG to avoid interoperability issues. Any further clarification for risks should consider existing regulations (e.g. prudential regulation in financial services) that must be complied with as well as possible future international sustainability reporting rules, which might otherwise become obstacles to interoperability. Finally, it would be desirable for the consideration of remedial or preventive actions to also apply to risks associated with material impacts. This would mean that a material risk linked to an impact that has been eliminated through a mitigation measure would likewise not need to be reported."]
["Survey","Institut der Wirtschaftsprüfer in Deutschland e.V. (IDW)","Auditor","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","The NMIG can be helpful, especially for first time adopters, to understand the methodological considerations of the ESRS Set 1. If the NMIG are to be intended as a long-term aid for companies, a robust due process for their development and maintenance should be established."]
["Survey","Institut der Wirtschaftsprüfer in Deutschland e.V. (IDW)","Auditor","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Regarding ESRS E1, the interaction between ESRS E1 and lease exemption in ESRS 1 from own operations is not clear. If the lease exemption were to apply to GHG reporting, the approach would not be consistent with financial control for lessors or lessees of operating leases, nor with RoU (local GAAP). When clarifying rules on whether and how the lease exemption is applicable for reporting on GHG emissions, consideration should be given to ensure a level playing field for all reporting undertakings. This would require consideration of comparable business models. There is also still an urgent need for clarification of how ESRS E1 rules interact with the GHGP and PCAF requirements and options. As the term \"shall consider\" has been kept, there is still room for interpretation. As is mentioned in the rationale for ESRS E1.AR39 a) (\"'Shall consider' was maintained as final wording, however varying views were received on whether it should be 'measured in accordance with', 'accounted for', and various other permutations.\"). Since EFRAG has acknowledged this uncertainty, a clear hierarchy of rules should be implemented in ESRS (e.g. for reporting boundaries, calculation methods and use of options provided in GHGP or PCAF). As the GHGP and PCAF are both internationally recognized standards, reporting GHG emissions under ESRS must remain comparable to reporting according to GHGP or PCAF. Consideration should be given to allowing undertakings to freely choose between the financial control and operational control approaches. Furthermore, clarifications in IFRS S2 regarding GHG emissions should also be taken into account."]
["Survey","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","I understand the intention behind reducing the number of datapoints, but I don't see this as a reduction in workload or reporting requirements in practice. The rationale given—\"Deleted for simplification purposes and reduction of datapoints. The provisions in ESRS 2 GDR-PAT apply to material topic and/or subtopic\"—does not translate into less work for us. Since the topic remains material according to ESRS 2 and GDR-PAT, we are still required to report on it. However, it's unclear where this reporting should take place if not within G1. We use a software (Position Green) that follows the structure of the delegated acts, and for simplicity and clarity, it would be preferable if these datapoints remained as Application Requirements (AR) under G1. This would help maintain structure and ensure that necessary disclosures are not lost. While I can appreciate the effort to reduce mandatory datapoints, I don't see how deleting PAT provisions from the topical standards but still requiring them in GDR actually reduces the workload. In fact, it creates ambiguity. Therefore, I would prefer these provisions to be retained as ARs in G1, as they offer valuable insights into company practices and ensure consistent reporting."]
["Survey","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden","22.E2.","Comments on deleted datapoints in ESRS E2","I agree","-"]
["Survey","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden","22.G1","Comments on deleted datapoints in ESRS G1","I agree","(Former G1-1 Disclosure Requirement related to ESRS 2 GOV-1 – The role of  the administrative, management and supervisory bodies) - It is good that it is handled in ESRS 2 GOV1 instead of seperated reporting in each topical standard."]
["Survey","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Important content of the topical standard and I appreciate the low reduction in datapoints. I would like to emphasize the need for intensity-based figures, that are now deleted."]
["Survey","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","We consider the proposed amendments under Level 3 to be a significant improvement. The restructuring of the architecture and the clarified interaction between ESRS 2 and the topical standards enhance the overall readability and usability of the standards. The simplification of the General Disclosure Requirements (GDRs), the reduction of mandatory datapoints for policies, actions, and targets (PATs), and the removal of overlapping topical specifications contribute to a clearer and more accessible framework. These changes reduce complexity and duplication, making it easier for preparers to navigate the requirements and focus on material information. In particular, the shift toward a more principles-based approach and the ability to report PATs at a higher aggregation level, reflects a pragmatic and proportionate response to the challenges identified during the first-time application. This supports more effective and relevant sustainability reporting, while maintaining the necessary level of comparability and transparency. In our point of view theses changes clearly promote readability, however it is important to note that those simplifications do not result in significant relief in terms of implementation effort or reporting complexity."]
["Survey","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","We strongly oppose both quantitative and qualitative disclosures of anticipated financial effects. The underlying data is often unclear, and the risks cannot be reliably isolated, making any form of disclosure—whether narrative or numeric—legally risky and prone to misinterpretation. Such information lacks comparability and does not offer decision-useful insights for stakeholders.  Moreover, IFRS already define when future risks and related current and anticipated financial effects must be reflected in financial reporting, e.g. through recognition and measurement criteria. Sustainability reporting should not override or extend these principles through financial disclosure requirements in the sustainability statement. We therefore recommend that this disclosure requirement should be removed entirely or made explicitly optional."]
["Survey","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","We support the removal of the datapoint on \"average time to pay an invoice,\" as it did not offer meaningful insights and was difficult to interpret in a decision-useful way.  However, we also question the relevance and practicality of the remaining datapoint on \"standard payment terms\" (former ESRS G1-6 §33b). In our view, this metric lacks clarity—especially in international contexts where no legal standard exists—and does not provide useful information for assessing supplier relationships. The percentage of payments made under \"standard terms\" is difficult to interpret and does not allow conclusions about actual impacts on suppliers. Also, disclosures on standard payment terms are already partially covered by existing financial reporting requirements, in particular IAS 7.44. As such, there is a risk of duplication between ESRS and IFRS requirements. To avoid inconsistencies and unnecessary reporting burden, alignment and clarification on the scope and purpose of such disclosures is essential. Furthermore, the categorization of suppliers (e.g., SMEs) remains problematic. Our financial systems do not track suppliers by size class, and iImplementing such a classification would require disproportionate effort.  Similarly, the requirement to report the number of legal proceedings due to late payments (former ESRS G1-6 §33c) is not decision-useful in isolation. Without qualitative context, such as reasons for delays or materiality thresholds, the raw number lacks relevance. Furthermore, we consider a material use case to be unlikely."]
["Survey","Kompaniets Consulting GmbH WPG","Consultant (including software vendor)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","(+) In the amended ESRS, numerous wording clarifications and editorial changes provide a clearer picture of what is expected under the requirements.  (+) It is evident that public feedback from the first reporting season has been incorporated into the amended ESRS.  (+) Including the Application Requirements (AR) in the main body of the standard increases readability. More precise cross-references to the related paragraphs increases understandability further."]
["Survey","Kompaniets Consulting GmbH WPG","Consultant (including software vendor)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","The reduction of more than 50% is significant. While we acknowledge the rationale for this drastic reduction, we stress that any further reductions risk watering down sustainability reporting requirements. In order to maintain a meaningful framework, the ESRS developtment should focus on clarifying requirements without deleting the existing ones."]
["Survey","Kompaniets Consulting GmbH WPG","Consultant (including software vendor)","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Overall, based on our analysis of the new ESRS, the simplifications and alterations are well designed.  We recommend no further decreases in the number, granularity, or scope of requirements, except for the suggestions above. Further reductions risk watering down European sustainability reporting.  In summary, our main points are:  (+) Maintain the double materiality assessment. It is key to meaningful sustainability reporting.  (+) The current simplifications strike a good balance between reducing complexity and preserving a well-crafted framework, though some changes go slightly too far. Sustainability reporting is inherently complex. Further reductions in ESRS requirements would likely water down reporting. Do not reduce further; instead use feedback to clarify requirements that are not fully understood.  (+) Make quantification of anticipated financial effects mandatory, with a phase-in period if needed.  (+) Reliefs, especially for entity-defined metrics, are too far reaching and should be conditional, with a phase-in period."]
["Survey","ACPR","National supervisory authority & regulator","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We support the decision to keep the Non-Mandatory Illustrative Guidance (NMIG) in a separate document. To support the evaluation of transition plans, the NMIG should specify the requirements under ESRS E1, including proposed granularity and units of measurement for activity volumes and greenhouse gas emissions, in accordance with IFRS S2, Appendix B – \"Industry-based disclosure requirements.\"  The diversification of the company's activities and its value chain should also be highlighted as adaptation levers, alongside measures to adjust working conditions in response to climate risks.  Additionally, the NMIG should mention the company's insurance coverage related to both transition and physical risks."]
["Survey","ACPR","National supervisory authority & regulator","France","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I agree","We support the incorporation of the information needed for the calculation of the SFDR PAI into the Amended ESRS. We also agree with the consolidation and clarifications of scope, as this improves relevance while also ensuring a significant reduction in datapoints. We also note that moving explicit disclosure requirements on company commitments to international social standards (UN, ILO, OECD) and on material negative impacts from the topical Social Standards to ESRS 2 could make these disclosures more generic and less specific by stakeholder group. However, these elements are referenced in SFDR and in the EBA guidelines at an aggregate level and  we therefore support the proposal to maintain them in ESRS 2 to ensure consistency with (prudential) reporting requirements in the financial/banking sector."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We generally agree with the proposed simplifications and clarifications of the DMA and we support the intention to make sustainability reporting more focused and less granular. In line with these objectives, we have the following three suggestions for further clarifications of ESRS 1: 1. It should be made clear that a combination of the top-down and bottom-up approach to the DMA is possible to apply. 2. Clarify that AR 21 of ESRS 1 applies to each sub-topic within a standard, i.e. if a material IRO relates to two or more sub-topics, the entity needs only to report on those sub-topics. There should be no exemptions to this principle (i.e. we do not agree with the exemptions in ESRS S1 paragraph 3). 3. The interaction between topics and IROs is addressed in paragraph 22 of ESRS 1. The paragraph explains the process of identification of topics in relation to IROs and the presentation of information at either topical or IRO level. As we understand the proposal, an entity should not always have to disclose the detailed connection between an IRO and a corresponding topic/subtopic. This is a positive improvement that will enhance more focused reporting. However, the principle should be more explicitly clarified to avoid lengthy discussions around interpretation with auditors etc."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","We welcome the amendments that will help entities avoid duplications in their reports and to disclose unnecessary details for pure compliance purposes. We believe that EFRAGs proposal will help entities focus on relevant and decision useful information. As we pointed out in our response to EFRAGs public call for input in the spring of 2025, there is a need for streamlining ESRS 2 and making the standard subject to materiality assessment. According to our understanding, EFRAGs proposal will accomplish this."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","22.E2.","Comments on deleted datapoints in ESRS E2","I disagree","General comment: The 57% reduction in mandatory datapoints does not correspond to an equal reduction in reporting burden as a large part of the more demanding disclosures and administrative requirements in the ESRS framework remain intact. There is significant room for further reductions on metrics, please consider the proposals for simplification jointly developed by BusinessEurope, EBF, Insurance Europe and EFAMA. When deliberating additional reductions, EFRAG should adopt a cost-benefit approach and remove such disclosures whose costs clearly exceed the benefits of the information.  Particular comment regarding ESRS E2: EFRAG should consider further simplifications and improvements of the E2-5 disclosure on substances of concern and substances of very high concern. We suggest further alignment with REACH and clarifications regarding the application of the disclosure for entities whose main activity is not within the chemical industry."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","22.S2","Comments on deleted datapoints in ESRS S2","I disagree","General comment: The 57% reduction in mandatory datapoints does not correspond to an equal reduction in reporting burden as a large part of the more demanding disclosures and administrative requirements in the ESRS framework remain intact. There is significant room for further reductions on metrics, please consider the proposals for simplification jointly developed by BusinessEurope, EBF, Insurance Europe and EFAMA. When deliberating additional reductions, EFRAG should adopt a cost-benefit approach and remove such disclosures whose costs clearly exceed the benefits of the information."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","We agree with the proposed change, that we expect will be a minor simplification in comparison with the current methodology."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","There is room for further simplifications. EFRAG should particularly look into further simplifications and improvements of the E2-5 disclosure on substances of concern and substances of very high concern. We suggest further alignment with REACH and clarifications regarding the application of the disclosure for entities whose main activity is not within the chemical industry."]
["Survey","Confederation of Swedish Enterprise","Business association (other than association of financial institution)","Sweden","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","There is room for further simplifications."]
["Survey","CNA","Business association (other than association of financial institution)","Italy","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","CNA","Business association (other than association of financial institution)","Italy","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","Not necessary"]
["Survey","CNA","Business association (other than association of financial institution)","Italy","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","CNA","Business association (other than association of financial institution)","Italy","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We generally welcome the increased flexibility introduced through the proposed amendments to the ESRS Sustainability Statements.   The possibility of including an executive summary and the emphasis on using appendices to separate detailed information from key messages can be helpful steps toward improving readability and structure. The option to include non-material information, if presented clearly, is a good step to maintain continuity for stakeholders.   However, we understand these changes primarily as clarifications rather than substantial simplifications. From our perspective, they do not result in significant relief in terms of implementation effort or reporting complexity. We do not consider that the removal of data points can be considered deletions, as they were duplicated in the first place.   Additionally, certain disclosure requirements continue to be embedded in application requirements, which could benefit from further reduction efforts. Please ensure that that application requirements don't consist of any disclosure requirements."]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","We acknowledge and welcome the improved structuring and consolidation of the ESRS requirements. The clearer separation and grouping of datapoints, especially the removal of voluntary datapoints and the streamlining of narrative PAT disclosures, enhances the usability of the standards.  However, we would like to emphasise that the reduction in the number of datapoints does not necessarily translate into a proportional reduction in the substantive reporting scope or effort.   In our view, the overall scope and complexity of the disclosures remain largely unchanged. The deletion of datapoints primarily affects how requirements are presented, not what is required. This means that preparers will still need to collect and disclose a substantial amount of data, and the core reporting obligations are largely preserved. The deletion of duplicated datapoints does not represent a reduction in effort.   Based on the Exposure Draft, we do not expect a significantly reduced reporting volume under the amended ESRS. Instead, the changes may help reduce effort in data collection, documentation, and coordination with auditors. For example, the introduced options for burden reliefs may simplify internal discussions and reduce the need to justify the omission of non-material items. It is important that this distinction is clearly communicated: while the number of datapoints has decreased, the underlying disclosure obligations remain intact. This will help manage expectations and avoid misinterpretations regarding the actual simplification impact of the amendments.  Moreover, we do have strong concerns regarding the new mandatory disclosure requirements that have been introduced and would request deleting them all to fulfill the purpose of the revision of the ESRS."]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","22.S2","Comments on deleted datapoints in ESRS S2","I disagree","See comments in \"Comments on deleted datapoints in ESRS2\""]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","We strongly disagree with introducing new mandatory datapoints that have not been comprehensively tested by \"Wave 1\" companies. Adding untested requirements at this stage threatens the strength, coherence, and successful implementation of the CSRD. We particularly object to ESRS E2-4, which is unworkable, unmeasurable, and unauditable: 1.\tBeyond company control – secondary microplastics occur post-consumer (UV radiation, abrasion, degradation), outside company influence. 2.\tImpossible data collection – no methodologies exist to reliably estimate how many products enter the environment or the volume of secondary plastic releases. 3.\tAuditability concerns – without standardised methods, reported figures would be speculative and unverifiable, undermining audit credibility. Furthermore, new concepts intended as reliefs—such as \"fair representation,\" \"Gross vs Net,\" or amending base years after acquisitions—risk adding complexity and burden without addressing these datapoints. Other new requirements that should be eliminated include: •\tESRS E5-4 para. 15(e): % of sustainably sourced materials by weight. •\tESRS E1-2 para. 19: introduction of \"spatial resolution.\" •\tESRS E1-3 para. 21(c): ability to adapt strategy and business model to climate change over time. •\tESRS E1-5 para. 24(c): stricter provisions on financial resources for climate actions. •\tESRS E1 AR 26: new disaggregation for CO2 emissions. •\tESRS G1-2 para. 10(c): extension of training to \"business conduct\" beyond corruption and bribery."]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","We support the removal of the datapoint on \"average time to pay an invoice,\" as it offered limited insights and was difficult to interpret usefully. A focus on PATs better aligns with fair presentation. The previous approach, framing SMEs as risky suppliers, added unnecessary barriers by introducing size-based vetting. However, we also question the relevance and practicality of the remaining datapoint on percentage of payments aligned with standard terms (former ESRS G1-6 §33b). This metric is difficult to consolidate, particularly in international contexts with no legal standard, and provides little meaningful insight into supplier relationships. The percentage of payments under \"standard terms\" is hard to interpret and yields no useful conclusions on supplier impacts. Categorisation of suppliers, such as SMEs, remains problematic. Financial systems rarely track supplier size, and implementation would require disproportionate effort. Similarly, reporting the number of legal proceedings due to late payments (former ESRS G1-6 §33c) is not decision-useful without qualitative context (e.g. reasons for delays or thresholds of materiality). For significant cases, this is already covered in legal risk reporting and need not be duplicated in sustainability reports. Finally, while qualitative information on payment practices can demonstrate SME protection, the calculation of G1-6 metrics is overly complex for international groups with diverse payment standards. Overall, deletion of the datapoint appears the most viable option."]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","European Round Table for Industry","Business association (other than association of financial institution)","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The glossary still requires significant review to incorporate new terms. It is critical for both preparers and auditors, yet contains errors (e.g., \"materiality consists of financial materiality and materiality\" in double materiality).  Specific comments include: •\tESRS 1, para. 11: The requirement for sector comparability is challenging due to business model variations. This may create issues for auditors. We suggest removing this or changing it to 'may' with NMIG as a minimum. •\tESRS 1, para. 84(c): We disagree with this provision which mandates organizational change. Adjusting baseline years should be determined by company policies, not mandated. For example, many companies achieve target progress by reshaping portfolios. Para. 72's relief, requiring inclusion in the \"subsequent\" period, is impractical. •\tESRS 1, para. 84(c) wording: This specific language is not found in IFRS S2, although it originates from the GHG Protocol. •\tESRS 1, para. 70: We disagree with the revised lease treatment in ESRS 1, as it creates challenges in data collection and traceability. We recommend basing reporting on operational control, not legal ownership, to better reflect impact management and reduce reporting burdens. Further clarification on leased assets in paragraph 70 is needed.  •\tWe also want to flag references to the 1.5°C target in the E1 transition plan provisions, particularly the long-term temperature goals of the Paris Agreement. While this is a Level 1 issue, we believe it warrants further review. •\tValue Chain: Assessing value chain impacts and data collection beyond Tier 1 remains difficult. Quantitative evaluation is often complex and insignificant, so reporting material facts when known is more practical than detailed assessments."]
["Survey","Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV)","Association of financial institutions","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","We support the simplification of disclosure requirements for anticipated financial effects due to the complexity, uncertainty, and sensitivity of corresponding quantitative data. We would have preferred this topic to be introduced as a phase-in provision under the revised ESRS. As this has not been considered it results in significant additional effort for companies at this stage Option 1 raises several concerns, including high estimation uncertainty. Further, while option 1 is substantially aligned with the IFRS relief, it includes deviations that may lead to additional reporting burden and efforts for undertakings aiming to comply with both standards. If option 1 is implemented, we therefore suggest to fully align option 1 with the IFRS provisions, i.e. by: (1) deleting the specification that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Even though such a relief would also be applicable under IFRS, any difference in the wording of the provisions can create additional effort on the reporting undertaking's side. (2) including the provision that the undertaking may omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information. We cannot agree to the concern that the relief is not compatible with entities that are expected to be in scope of the amended ESRS. This judgement should be at the undertaking's discretion. Even though larger undertakings can be expected to have the necessary skills, capabilities, and resources, there may be cases in practice where such preconditions are not existent, given the complexity and lack of maturity for related disclosures. Choosing from the two options as they are provided, we recommend implementing Option 2, which focuses on qualitative disclosures and allows voluntary quantification."]
["Survey","Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV)","Association of financial institutions","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We support the review of AR 26 in Amended ESRS E4, insofar as it contributes to the overall simplification of the standard and maintains a degree of methodological guidance that can assist undertakings in defining relevant biodiversity and ecosystem-related targets. This being said, the current target-setting guidance in E4 AR 26 is primarily oriented towards the real economy, focusing on direct actions such as habitat restoration or number of projects/sites, which are applicable to production sectors. However, for financial institutions, biodiversity targets are rather connected to portfolio alignment, sector inclusion, engagement targets, or impact reduction based on metrics disclosed by investees, empha sizing the shift of capital flows rather than direct operational control. Therefore, any guidance included in a revised AR 26 on target setting will struggle to capture the diverse requirements across sectors. Given this disparity, we suggest not including specific target guidance in the ESRS, allowing flexibility for each sector to define targets that are relevant to their unique roles and impacts on biodiversity and ecosystems."]
["Survey","Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV)","Association of financial institutions","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","We welcome the deletion of this voluntary data point."]
["Survey","IOGP Europe","Business association (other than association of financial institution)","Belgium","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","In general, we agree with the improvements performed and welcome the proposed amendments aimed at enhancing the clarity and accessibility of the ESRS. However, further simplification and precision are needed to improve usability and avoid confusion, particularly with auditors.   Unclear and contradictory terminology should be eliminated. For instance, terms such as \"shall consider\" create ambiguity: \"shall\" implies mandatory action, while \"consider\" suggests discretion. This phrasing leaves room for interpretation and could result in inconsistent application or auditor disputes. Similarly, application requirements (ARs) that use \"may\" should be removed, as \"may\" implies voluntary action, which contradicts the stated objective of eliminating voluntary disclosures. Clear, mandatory language is essential to ensure consistency and enforceability across undertakings.   Clarification of key terminology is required. For example, the term \"significant\" is currently ambiguous. We recommend explicitly stating that undertakings determine significance based on their specific business model and context, ensuring disclosures remain relevant, material, and decision-useful.   These targeted adjustments will simplify the Standards, improve their practical application, and ensure the framework remains principles-based, enforceable, and aligned with the goal of reducing complexity for preparers while maintaining comparability and reliability for users."]
["Survey","IOGP Europe","Business association (other than association of financial institution)","Belgium","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets\t   Absolute emissions targets are not decision-useful in this context. The GHG Protocol, while the accepted basis for reporting, has significant limitations when applied to target-setting: it can double-count across Scopes 1, 2, and 3, fails to capture avoided emissions, and lacks product-level granularity. This penalises companies that scale low-carbon solutions such as hydrogen, LNG switching, or carbon capture, while discouraging innovation. Intensity targets, by contrast, provide a more accurate and comparable view of performance, reflecting efficiency and progress without distorting incentives. For financial institutions, requiring associated absolute values would add burden without improving transparency and risks misleading stakeholders."]
["Survey","IOGP Europe","Business association (other than association of financial institution)","Belgium","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We recommend eliminating the disclosure requirement on anticipated financial effects in ESRS 2. Preparers are not yet sufficiently equipped to provide reliable forward-looking financial data and there are significant concerns that such disclosures could expose commercially sensitive information. In practice, the current formulation risks overburdening companies with requirements that cannot be met at the desired level of quality. This may result in disclosures that are speculative, inconsistent, and potentially misleading for users, undermining the reliability and decision-usefulness of sustainability reporting. We strongly encourage the removal of this requirement until more robust methodologies, systems, and assurance practices are in place.   Regarding ESRS 2 GDR-P for S1-S4, we note that the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises are important international frameworks, but they are not legally binding on businesses. To ensure both accuracy and legal clarity, we recommend amending the reference in the disclosure requirement. Specifically, when describing an undertaking's overarching human rights policy, the current wording \"committing to implement\" these frameworks should be replaced with \"committing to respect for human rights aligned with\" these frameworks. This is consistent with our concern raised under the SFDR datapoints (Q29) regarding human rights policies, where overly prescriptive wording risks creating unintended behavioural requirements.   This revision would ensure alignment with international best practice, while avoiding the implication that undertakings are legally bound to implement instruments that have no binding legal force. It also ensures consistency with the language commonly used in corporate human rights commitments, providing clarity for preparers and auditors while supporting meaningful transparency.   Eliminating anticipated financial effect disclosures and refining the language on human rights commitments would enhance the feasibility, accuracy, and credibility of ESRS 2 reporting requirements, while maintaining interoperability with ISSB standards."]
["Survey","IOGP Europe","Business association (other than association of financial institution)","Belgium","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","For all the social standards, we stress the importance of maintaining the reference to \"severe\" human rights incidents within the disclosure requirements. Removing the qualifier \"severe\" significantly broadens the scope of reportable incidents. Given the breadth and complexity of the human rights domain, such an approach risks obliging undertakings to disclose numerous less relevant or minor issues. This would not only dilute the significance of reporting but also create confusion during the selection of information to be disclosed. Importantly, this expansion contradicts the spirit of the ESRS simplification exercise by adding unnecessary reporting burden. A focus on severe human rights incidents ensures that disclosures remain meaningful, proportionate, and aligned with the principles of relevance, efficiency, and decision-usefulness."]
["Survey","LMU","Academia","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","The removal of the category of \"may datapoints\" is positive as those caused confusion and could have contributed to diverging, non-comparable reports.  The wording has also become clearer in general. However, the move to more principles-based reporting has also led to examples and method explanation being in part removed or put into the NMIG. While from a researcher/data user perspective this is, at first, not problematic, there is the danger that data preparers might disclose idiosyncratic information that is hard to compare and aggregate as guidance and examples are harder to find."]
["Survey","LMU","Academia","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","From a research perspective the NMIG do only matter indirectly insofar as their use or non-use could influence the comparability and quality of disclosures. As such, my main comment would that they should probably be presented more as a Question-Answer document for preparers and less as a residual category for datapoints that were deleted."]
["Survey","LMU","Academia","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The new definition of the threshold is simpler to interpret and to communicate."]
["Survey","LMU","Academia","Germany","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"My answers to this questionnaire are largely on data quality considerations regarding sustainability disclosures and an emphasis on georeferenced disclosures. The latter matter from a perspective of construct validity, allow for great interoperability with existing datasets from remote sensing and administrative data and enable users outside of the financial system (e.g. environmental agencies, urban planners) to use the data for their activities.  I elaborate in more detail on these points in Sommer and Dimmelmeier (2025) https://greendia.de/wp-content/uploads/2025/09/greendia_efrag_policy_brief_09_11.pdf  and in Dimmelmeier, Sommer and Cooke (2024). https://sustainablefinanceobservatory.org/resource/reframing-the-eu-landscape-for-corporate-sustainability-information/"]
["Survey","Allianz SE","Insurance","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We support eliminating most \"may disclose\" datapoints to enhance focus and reduce confusion. We welcome the relocation of all mandatory disclosure requirements into the main body of the standards, along with the placement of application requirements directly below each relevant DR and Chapter in ESRS 1.  However, our remaining concerns include: 1) Some \"may disclose\" datapoints remain (e.g., ESRS 1.114, 1.115) and should be reconsidered to ensure consistency in mandatory reporting.  2) ARs are intended to constitute mandatory requirements, and that all guidance or illustrative examples should be moved to the NMIG. -\tChanges to established terminology should be approached with caution, given that many undertakings are already preparing or reporting under the original ESRS. The consistent use of \"material IROs\" should be ensured across the standards, avoiding references to \"material topics,\" and wording should not alternate between \"adverse\" and \"negative\" impacts.  3) We remain concerned by the wording of certain ARs. Expressions such as \"shall consider\" create ambiguity, as it is unclear how \"consideration\" can be measured or audited, and such phrasing risks prescribing behavior in contradiction with ESRS 1 paragraph 5."]
["Survey","Allianz SE","Insurance","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","The disclosure of absolute values alongside GHG emissions intensity targets presents significant challenges for financial institution and it fails to comply with qualitative characteristic of information: Estimating absolute emissions associated with an intensity  target   involves assumptions about portfolio composition, production capacity, market shares, and emission intensity, leading to unreliable results and unmeaningful disclosures. On top of that, absolute emissions associated with an intensity target    may capture total impact but fail to consider business growth, potentially creating an unlevel playing field if exceptions are made only for financial institutions. We agree with the exception for financial institutions due to the unique role they play in facilitating sectoral transitions."]
["Survey","Allianz SE","Insurance","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Allianz SE","Insurance","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Overall feedback to S standards: alignment with CSDDD: o\tConsistency and compatibility between CSRD and CSDDD needs to be ensured, o\tthrough use of consistent definitions, o\tsupport for risk-based due diligence and such processes qualifying as \"actions\" in the system of PAT in addition to preventive and remedial actions. o\tallowing different granularity of materiality in S1/S2/S3 to align with CSDDD principle of risk-based due diligence."]
["Survey","Allianz SE","Insurance","Germany","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","ASSIREVI - Association of the Italian Audit Firms","Auditor","Italy","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","We do welcome the amendments presented to align the provisions and avoid unnecessary differences between the ESRS and the ISSB. Particularly, despite the difference in materiality perspective which was not changed (ESRS relies on double materiality - in contrast to IFRS that relies on financial materiality only) the concept of the \"materiality of information\" has been reinforced (ESRS 1 Chapter 3.1 new par. 21) becoming a general filter for the reported information, meeting users' needs and expectations and aligning to ISSB. Some existing differences related to the ESRS E1 and ISSB S2 have been addressed, such as the revision of the languages to adopt the same terminology of ISSB (i.e. transition plans, resilience, internal carbon pricing, anticipated financial effect/opportunities); the removal of MDR would permit EFRAG to align the content areas with the ISSB's approach.  However there remain some differences: some disclosure requirements and reliefs/proportionality mechanisms have partially been brought into the proposals, but not fully or without the complete accompanying application guidance; furthermore, the allowance for the inclusion of non-material information (ESRS 1 para. 108), if confirmed, would undermine the core principle of materiality - the cornerstone of ESRS - and could weaken interoperability with the ISSB standards; some of the information required by ESRS E1-11 are additional with respect to ISSB S2.  Failure to achieve the greatest possible alignment between ESRS and ISSB standards would be contradictory with the objective of reducing the reporting burden. Consideration should be given to undertakings that will be required to disclose under both frameworks, as well as the difficulties to obtain exemptions for subsidiaries in jurisdictions with mandatory ISSB application.  Considering some misalignments will inevitably persist, we believe it's essential to update the interoperability guidance to provide concrete support for preparers applying both the frameworks."]
["Survey","ASSIREVI - Association of the Italian Audit Firms","Auditor","Italy","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","We believe that the reduction of mandatory datapoints proposed in the EDs is an acceptable compromise between the objective of simplification and the information needs of users of the sustainability report."]
["Survey","ASSIREVI - Association of the Italian Audit Firms","Auditor","Italy","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We believe that the decision to add new mandatory datapoints to ESRS E3, ESRS E4 is acceptable. On the specific proposal to require mandatory disclosure of a transition plan for biodiversity and ecosystems if such a plan exists, we are concerned by difficulties in assessing whether an undertaking plan would be considered a \"transition plan\" (as opposed to an extension of strategic policies, actions and targets). If mandating disclosure, we think it is important that the standards include within the glossary the definition of transition plan for biodiversity and ecosystems.  With regard to the proposal to add to ESRS G1 a mandatory datapoint that provides for the separate indication of the participants to the training activity, we believe that this change does not add relevant information, entailing a burden both for preparers in the collection of detailed information, especially within groups, and, consequently, for assurance providers who must then verify the information provided\". Regarding the proposal to add to ESRS G1 a quantitative mandatory datapoint on confirmed incidents of corruption and bribery, we recommend that the definition of corruption and bribery be better clarified in particular when the company operates in different jurisdictions. We also recommend clarifying what constitutes a \"confirmed incident\", in case of more than one level of judgment."]
["Survey","ASSIREVI - Association of the Italian Audit Firms","Auditor","Italy","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","We agree with all three critical points raised by EFRAG SRB members. On the other hand, we believe that the request for alignment/reference of collective agreements or estimates on the minimum wage mentioned in points i), ii) and iii) with the ILO principles can represent a guarantee of the adequacy of the calculation methodology adopted. However, the methodology for the calculation of adjusted wages as amended and defined in § AR 22 (b) of ESRS S1 is not entirely consistent with the objective of the DR as it allows the use of the statutory minimum wage established by legislation or collective agreements, provided that these are reviewed and take into account the ILO principles on wage determination. Moreover, the reference to be used is not entirely clear, since § AR 22 (b) mentions the \"ILO principles on wage determination\" in point (i) of the paragraph, and the \"ILO principles for the estimation of a living wage\" in point (ii). It is therefore useful to clarify the methodology (e.g. ILO) to be used, to strengthen the guarantee of adequacy and ensure the correct application of the calculation, and to develop more guidance in order to make these references effectively used by companies in a consistent manner. Given the complexity of the issue and the fact that a benchmark for the appropriate salary is not always available, it is recommended to emphasize, within the DR, the importance of providing sufficient qualitative information to explain the methodology applied. Finally, we believe that the field test envisaged to assess the adequacy and applicability of the methodology is a necessary exercise, especially if implemented on a large scale, to include as many exceptional cases as possible. This will help to verify the correctness of the methodology adopted or, possibly, to highlight the critical application issues."]
["Survey","ICAEW","Auditor","United Kingdom","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","We consider that ESRS should be a fair presentation framework and are supportive of amendments to clarify this. However, we note that the language used to describe what is meant by fair presentation differs from the ISSB's definition. We would support full alignment with the ISSB's language, which mirrors the financial reporting definition and is therefore widely understood. We also suggest that EFRAG reviews the implications of clarifying the fair presentation framework within the context of other requirements.  For example, requirements to provide entity-specific information is already embedded within the fair presentation requirement (as it is in the ISSB Standards), and is therefore difficult to understand why it remains a separate requirement. Similarly, it is difficult to understand how the proposed relief regarding the reporting of acquisitions and disposals interacts with the fair presentation framework. We would expect that a reporting entity that makes a material acquisition or disposal during the year should disclose sustainability information related to that acquisition under a fair presentation framework.  We accept that it may be difficult to acquire that information at the same level of detail as businesses owned for a full year but would expect that reasonable estimates should be possible and that uncertainties associated therewith could be disclosed and, where necessary, restated later.  This would more closely mirror fair presentation requirements in financial statements."]
["Survey","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The introduction of the \"undue cost or effort\" relief is a critical step towards acknowledging the practical challenges of sustainability reporting. This measure provides much-needed flexibility for companies when collecting data, particularly for metrics and value chain information. We also support the relief for a lack of data quality, which allows for partial scope reporting while requiring companies to disclose actions for future improvements.      Despite these positive changes, the amendments still fall short of providing sufficient relief.   The definition of \"reasonable\" effort is open to differing interpretations, which could lead to disagreements with auditors. Clearer, more specific guidance is needed to ensure consistent application and to prevent a new source of complexity.   Further simplification is essential for supply chain reporting. Companies should be required to report only on their own targets, actions, policies, and metrics. Data from the supply chain should be required only to the extent that it directly relates to the company's own commitments. Companies should not be obligated to collect detailed, granular data from suppliers or customers, as this is often not feasible or proportionate.   The relief measures should also apply to smaller subsidiaries (e.g., those with fewer than 50 or 20 employees). These subsidiaries face similar challenges as SMEs in gathering sustainability data, and their inclusion in relief provisions would significantly reduce the burden on corporate groups."]
["Survey","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","No, we do not agree that these exceptions are appropriate and justified. The move of six \"may\" datapoints to \"shall\" contradicts the EU's simplification agenda and unnecessarily increases the reporting burden by introducing more binding requirements.   For example, mandating the disclosure of training for the procurement team in ESRS G1 10(c) is questionable. In our view, this datapoint does not necessarily create significant added value, as the assignment of responsibilities within a company can be highly individualized. The focus should remain on key positions in terms of compliance training, rather than prescribing specific teams."]
["Survey","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","SZEF - Szakszervezetek Együttműködési Fóruma","Trade union","Hungary","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The Exposure Draft removes duplications between the cross-cutting and topical standards. The preservation of the 4-part architecture in the social standards is important to respect the distinctiveness of different affected stakeholder groups.    However, we have two critical concerns. First, the original DR in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. We welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened. Second, we strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics should not imply that entity-specific metrics for S topics should not be disclosed."]
["Survey","SZEF - Szakszervezetek Együttműködési Fóruma","Trade union","Hungary","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The ability to estimate financial effects is critical for the undertaking's ability to integrate sustainability into its business strategy considerations, planning and risk management. It is also key for the determination of financial materiality, including in terms of overreporting topics as financially material. Reporting on financial effects is crucial to achieving the objective of putting sustainability reporting on the same level as financial reporting and integrating both. The European Union has recognised the value of a double materiality approach to corporate reporting which requires disclosure of both material environmental and social impacts, risks and opportunities as well financially material data, It is important to keep the requirement on businesses to analyse and understand the financial effects of their business model. This will ensure investors have access to credible data as well as providing the underpinning for future business planning."]
["Survey","SZEF - Szakszervezetek Együttműködési Fóruma","Trade union","Hungary","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","The \"fair presentation\" principle is essential to reduce the risk of green/social washing, as it emphasizes the full disclosure of all material impacts, risks and opportunities and their management. It is not understandable why this principle is under attack, as it is included as one of the general principles of the Accounting Directive."]
["Survey","SZEF - Szakszervezetek Együttműködési Fóruma","Trade union","Hungary","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","ESRS 2: The improved language on DMA is welcomed, including on the engagement with workers' representatives."]
["Survey","BASF SE","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Despite the welcome simplifications for the double materiality assessment, the burden faced by companies already report based on ESRS will not change significantly in the short term.   2. This is a valuable clarification for companies in streamlining the reporting and reducing the audit burden.   3. Some of the wordings lack clarity and invites interpretation, which could create divergent approaches between reporting companies and might cause discussions with the auditor. In particular:  3.2 (22): \"The information shall be presented either at topical level or at impacts, risk and opportunity level\".  It should be clarified that presenting data at either the IRO or topic level should be acceptable.  •\t3.3.1 (34): \"Actual impacts in the reporting period include both newly arisen impacts and those persisting from previous periods\". The lack of specification over how many previous periods should be included leaves far too much room for interpretation. Companies should have the ability to pragmatically assess material impacts from previous periods that remain relevant, in line with a more principles-based approach. The sentence should be removed.  •\tPar. 30/AR6 – Identifying (and assessing for severity and likelihood) whether impacts occur that may be connected to an undertaking's products through multiple tiers of the value chain remains a requirement that cannot practically be executed. We recommend focusing on tier-1 value chains and reporting only if there's sufficient confidence about the impact's occurrence, severity, and likelihood.  4. Confirmation is needed that \"non-material\" information should not be subject to the assurance regime applicable to the CSRD.  8. We agree on using reasonable, supportable information without undue cost or effort, but it's unclear how this aligns with Chapter 3.7. The level of aggregation or disaggregation should be determined by the level most relevant to the material IRO."]
["Survey","BASF SE","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","We strongly oppose both quantitative and qualitative disclosures of anticipated financial effects.   The underlying data is often unclear, and the risks cannot be reliably isolated due to a lack of mature and established methodologies, making any form of disclosure - whether narrative or numeric - legally risky and prone to misinterpretation. Such information lacks comparability and does not offer decision-useful insights to report to users from our point of view. Moreover, IFRS already define when future risks must be reflected in financial reporting, e.g. through recognition and measurement criteria. Sustainability reporting should not override or extend these principles through financial disclosure requirements in the sustainability statement. We therefore recommend that this disclosure requirement be removed entirely or made explicitly optional.  It should also be noted that even for a qualitative statement on anticipated financial effects a quantitative assessment needs to be done.   Also, qualitative information is subject to a high level of uncertainty but there is less likelihood of unjust comparison. This begs the question of what use this information could have for any stakeholder, esp. capital market participants."]
["Survey","BASF SE","Preparer (non-financial preparing a sustainability report)","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","We strongly disagree with the introduction of new mandatory datapoints that have not been proven necessary. Adding untested requirements at this critical stage poses a significant liability to the strength, coherence, and successful implementation of the CSRD. It contradicts the simplification mandate and risks undermining reliable sustainability reporting.  We do not agree with the decision to make \"Nature of incidents\" and \"Number of incidents\" within ESRS G1 paragraph 14 (confirmed incidents of corruption and bribery) mandatory.   Firstly, making additional quantitative datapoints mandatory will increase burdens. Quantitative data collection requires IT development or manual reporting, which are costly and time consuming.   Secondly, the \"may\" provision for such sensitive data points allowed for necessary discretion. The specific context of each incident, might not be adequately conveyed by a simple numerical count or a brief description. The focus should be on the effectiveness of management systems in preventing and addressing corruption, not a potentially reductive tally of past failings.   G1 Training datapoint will add complexity as companies evaluate the risk exposure of functions individually and then derive training needs from that. In cross-functional training settings it is close to impossible to derive that information. This data point should not be made mandatory. For G1 paragraph 14, it's unclear how materiality should be assessed—by monetary value or other criteria? What incidents need reporting (e.g., court decisions)? This datapoint should also be deleted."]
["Survey","BASF SE","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","We recognise the critical importance of ensuring adequate wages globally. However, we have significant concerns regarding the proposed benchmark hierarchy for non-EU wages in ESRS S1 AR 22.  The current hierarchy, which places living wage datasets as a \"last resort,\" undermines comparability. It permits companies to report against statutory minimum wages that may be insufficient, resulting in inconsistent and incomparable data. This hampers stakeholders' ability to make fair assessments of a company's social impact.  We propose revised wording for AR 22, para. 32. For reporting outside the EEA, the first step should require an \"adequate minimum wage\" rather than a \"statutory minimum wage,\" and it should align with the definition of adequate wages in Directive (EU) 2022/2041.  Without this adjustment, comparability will be impossible, as some companies will report on 'minimum wage' while others will report on 'adequate wage.'  It is essential to have a single, authoritative reference for defining an adequate wage. Allowing companies to choose different providers could lead to inconsistent and non-comparable disclosures, ultimately compromising data quality. Creating a common database of adequate wages for all companies to refer to is critical. This would ensure comparability across jurisdictions and reduce the burden on companies in determining what constitutes an adequate wage in each country where they operate.  Moreover, we anticipate that an extensive workload could emerge from the following phrase \"periodically reviewed/adjusted every two years and takes into account the ILO wage setting principles.\" Indeed, as the indicator covers the entire workforce, an assessment would have to be conducted in all countries of operation to check the fulfilment of these two new criteria. Furthermore, should a company operate in different sectors of activity, it might have several collective agreements to check within a single country. Ultimately, this could lead to hundreds of checks to be performed."]
["Survey","BASF SE","Preparer (non-financial preparing a sustainability report)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","ESRS E4 raises significant concerns due to the level of detail required and the potential for excessive disaggregation of IROs unto site levels or even below.   These requirements risk imposing disproportionate reporting efforts, especially in the case of biodiversity, where it remains unclear how to prioritize which sites to disclose.  In particular, the newly introduced Application Requirement AR 8 in ESRS E4 would effectively require companies to conduct ad hoc analyses for hundreds of sites—specifically those not overlapping with biodiversity-sensitive areas—in order to identify a science-based buffer zone tailored to the ecological specificities of each site. Such a requirement represents an operational and documentation burden that is entirely disproportionate to the stated goal of simplification. It risks undermining the usability and clarity of the sustainability statement, especially when the prioritization logic is not clearly defined."]
["Survey","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","The TNFD supports EFRAG's efforts to reduce the reporting burden by streamlining the number of datapoints, particularly where this removes duplications or overly prescriptive narrative requirements. We recognise that such simplification can help undertakings focus on reporting decision-useful information in a more efficient and consistent manner.  At the same time, we encourage EFRAG to ensure that this reduction does not come at the expense of alignment and consistency with the TNFD recommendations, particularly in relation to nature-related disclosures, including disclosure metrics, where the need for structured and comparable data remains critical.  TNFD's detailed comments and concerns on individual datapoints we suggest be retained are included in Part 3."]
["Survey","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom","35.ESRS2_GDR-T."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","There is a weakening of the language on reporting of progress and review of targets (paragraphs 80.i and 80.j of Set 1), reducing alignment with the TNFD recommended disclosure Metrics and Targets C: o\tParagraph 80.i previously asked about whether the target or metrics had changed since the last report. This is a broader requirement than the TNFD recommended disclosure, which only asks \"If the organisation exceeded or fell short of the target trajectory or is projected to do so, an explanation of the reasons and disclosure of any resulting adjustment or resetting of targets from the prior period\". However, the replacement text in ESRS 1 and BP-2 appears to focus on rectification of errors and changes in data, rather than revision of targets per se.  o\tParagraph 80.j previously asked about, \"the performance against its disclosed targets, including information on how the target is monitored and reviewed and the metrics used, whether the progress is in line with what had been initially planned, and an analysis of trends or significant changes in the performance of the undertaking towards achieving the target\".  This was slightly more specific than the TNFD recommended disclosure, which asks for disclosure information on, \"Performance against the target relative to the baseline or reference condition on a historical and current year basis, updated annually, and expected performance against targets for the following year, where appropriate\".  However, the ESRS text in the amended ED has now been reduced, in new paragraph 42, to \"overall progress and effectiveness towards the adopted targets over time. This includes - where applicable - whether the progress is aligned with related action plan and/or whether any significant facts and circumstances related to the action plan affect the achievement of the target.\"  This misses the frequency of reporting and expected future performance.","ESRS2","General Disclosure Requirement for targets - GDR-T",""]
["Survey","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom","35.E5-4."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","Rather than removing important specifications that would guide undertakings in the identification of relevant metrics, the TNFD suggests EFRAG consider simplification of datapoints for E5 by explicitly aligning the nature-related metrics listed under DR E5-4 and E5-5 with the resource use and circular economy-related 'core global metrics' (C2.2, C2.3, C3.1) from the TNFD that apply to all sectors on a comply or explain basis.  Additionally , the TNFD does not support the proposed removal of the following requirement as it reduces alignment with TNFD Risk and Impact Management pillar: •\tDescription of methodologies used to calculate data and key assumptions used.","E5","Disclosure Requirement E5-4 - Resource Inflows",""]
["Survey","Global Standard gGmbH","Other - please specify (required)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","We appreciate the intention behind the amended ESRS to strike a balance between the reporting burden on undertakings and the need for relevant and comparable sustainability information. However, from a due diligence perspective grounded in the UN Guiding Principles, the OECD Due Diligence Guidance several tensions remain. 1.\tThere is a risk of under-disclosure. Reduced prescriptiveness may allow undertakings to omit or downplay material negative impacts, particularly where double materiality assessments rely heavily on internal definitions or lack robust stakeholder input. GOTS requires certified entities to identify and disclose salient risks regardless of internal prioritisation frameworks. 2.\tPreparation effort is essential for credible due diligence. While simplification can enhance accessibility, robust sustainability disclosure, especially on human rights and environmental risks, necessarily requires effort and investment. GOTS views comprehensive risk identification and stakeholder engagement as essential components of both due diligence and credible reporting. 3.\tThere is a need for consistent minimum expectations. For information to be comparable across companies and sectors, a certain level of baseline prescriptiveness is required. GOTS addresses this through its harmonised certification system, which sets minimum requirements that apply across diverse geographies and operations. Recommendation: ESRS should ensure that flexibility in reporting format or presentation does not compromise the quality or completeness of disclosures. Prescriptive elements related to impact identification, stakeholder engagement, and due diligence steps should be maintained or strengthened. EFRAG should also consider recognising credible voluntary sustainability standards (VSSs), such as GOTS, as supporting instruments that help companies demonstrate alignment with international due diligence frameworks."]
["Survey","Global Standard gGmbH","Other - please specify (required)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","Global Standard gGmbH","Other - please specify (required)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","We support the intention behind increasing country-level visibility of employee-related disclosures, such as characteristics of the workforce, collective bargaining coverage and social dialogue. These are important indicators for understanding labour rights risks and ensuring accountability. The change to a threshold based on the ten largest countries by headcount has the potential to provide more consistent information, but the balance is only partly achieved. The new criterion may exclude countries where headcount is relatively small but where salient risks are high, as is often the case in textile supply chains. For example, a brand headquartered in Europe may employ only a modest number of people directly in high-risk sourcing countries such as Bangladesh or Ethiopia, but those contexts remain critical for assessing collective bargaining and social dialogue. A threshold based only on headcount risks obscuring issues that are material from a rights-holder perspective. The Global Standard therefore recommends refining the threshold so that the ten largest countries are disclosed, but with the option to add other countries where material risks are present, regardless of headcount. This would ensure that disclosures remain both consistent and responsive to stakeholder-relevant risks. Recognition of credible voluntary sustainability standards such as GOTS can provide companies with tools to identify high-risk geographies and ensure that disclosures reflect international due diligence expectations."]
["Survey","Global Standard gGmbH","Other - please specify (required)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Global Standard gGmbH","Other - please specify (required)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","EFPIA","Business association (other than association of financial institution)","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","\"The changes bring some benefits. In particular, the simplification of PAT requirements helps make reporting clearer and less heavy for companies. This is a positive step towards reducing the workload and achieving a better balance between ESRS 2 and the topical standards.  At the same time, we are concerned about the duplication with the IFRS Sustainability Disclosure Standards (SDS). Many companies already report under IFRS/ISSB, and the overlap with ESRS means extra work, higher costs, and less efficiency. This duplication undermines the goal of simplification and makes reporting harder instead of easier.  To strike the right balance, we believe ESRS should be better aligned with the IFRS SDS global baseline. This alignment should focus on identifying and addressing specific gaps between the standards to improve interoperability, while maintaining double materiality.  Stronger alignment would reduce costs, avoid confusion, and improve comparability of reports across markets.\""]
["Survey","EFPIA","Business association (other than association of financial institution)","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","EFPIA","Business association (other than association of financial institution)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","We see value in providing guidance for setting biodiversity- and ecosystem-related targets. However, we have two key concerns:  Reference to ESRS sectors should be removed until the sector standards are finalised. Introducing such references prematurely creates uncertainty and risks inconsistency.  A broader re-review of ESRS E4, including AR26, is needed to ensure full interoperability and alignment with existing frameworks such as the Taskforce on Nature-related Financial Disclosures (TNFD)."]
["Survey","EFPIA","Business association (other than association of financial institution)","Belgium","35.E1-6."," Do you agree with the amendments of this chapter? ","I disagree","The current approach restricts companies from updating their baseline year except in cases of major changes to boundaries, which may prevent the use of the most accurate and relevant data—especially when organizations improve data quality or undergo substantive changes that do not strictly meet the set criteria. To ensure that disclosed climate targets are both meaningful and credible, I recommend that the ESRS allow greater flexibility for companies to choose or revise their baseline year when justified by improvements in data or organizational structure, provided such changes are transparently disclosed and explained. This adjustment would enable more accurate reporting and better reflect business reality without compromising transparency or comparability.","E1","Disclosure Requirement E1-6 - Targets related to climate change",""]
["Survey","IDH","Business association (other than association of financial institution)","Netherlands","35.S1-9."," Do you agree with the amendments of this chapter? ","I disagree","3 years of experience working alongside leading companies on adequate and living wage practices, we strongly support the ESRS objective to ensure employees are paid an adequate wage. To meet this objective, it is important to clarify that statutory minimum wages cannot, on their own, be considered sufficient to demonstrate adequacy. In most jurisdictions, minimum wages fall below the level required for a decent standard of living, and therefore do not align with ILO principles or with the intent of the ESRS.  For consistency with the benchmark hierarchy already set out, adequacy should be assessed against:  - Wages established through collective bargaining agreements, or  - Living wage benchmarks that directly reflect what workers and their families require for a decent standard of living.  This approach is consistent with the ILO's agreed principles on estimating living wages, reduces the risk of discrimination between EU and non-EU employees, and ensures comparability and credibility in company reporting. It also reflects the practical experience of leading businesses that recognize living wage benchmarks as the most reliable measure of adequacy.","S1","Disclosure Requirement S1-9 - Adequate wages",""]
["Survey","Deutscher Bauernverband e.V.","Business association (other than association of financial institution)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","International and European standards should be aligned."]
["Survey","Deutscher Bauernverband e.V.","Business association (other than association of financial institution)","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree"]
["Survey","Deutscher Bauernverband e.V.","Business association (other than association of financial institution)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Deutscher Bauernverband e.V.","Business association (other than association of financial institution)","Germany","35.ESRS1_5.2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree",null,"ESRS1","5.2 Inclusion of value chain information",""]
["Survey","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Moving the AR from the end of the standards to the corresponding DR is very helpful. Furthermore, we welcome the deletion of the \"may disclose\" requirements as well as the inclusion of all \"shall\" requirements within the main body. However, we clearly oppose the new mandatory datapoints implemented in the drafts.  There is no definition regarding \"when applicable\". We would like to suggest that reporting on such issues is only necessary if it is applicable. A company should not report any negative statements but instead simply not report.  Furthermore, it is crucial that terms are clearly defined, for example: shall consider, may present, may implement, … -> if the same meaning is intended we suggest to always use the same term throughout the standards in order to avoid confusion."]
["Survey","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","Overall comments:  In general we welcome the deletion of datapoints, however we would like to highlight the following issues:  -\tFor some disclosure requirements only granular datapoints have been deleted, the overall reporting requirements remain unchanged. This might lead to the same reporting amount as before as the definition of the requirements is just more open now. -\tThe changes made nonetheless lead to implementation efforts for companies to apply for the changes -\tSome mandatory datapoints have been shifted to NMIG  it should be clearly enforced that NMIG are no reporting obligation but should help implementation -\tAdditional new datapoints have been introduced, this clearly contradicts the EU mandate and these should therefore be deleted again"]
["Survey","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","We are of the opinion that an adjusted gender pay gap delivers important insights for companies to truly control based on this information and in the best case scenario to close the gender pay gap. Therefore, we recommend to include the adjusted gender pay gap metric in the standard as a \"may\" requirement. However, it should remain voluntary."]
["Survey","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","The G1-6 is not material for us, so this change hardly affects us. However, we do not think that a separate disclosure of a SME category is useful. Categories should be chosen according to relevance for the company"]
["Survey","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","ECIIA","Other - please specify (required)","Belgium","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","G1","Disclosure requirements  Internal Audit is  independent (see Three Lines Model above), is professional  (certifications…) and is required to comply with the International Professional Practices  Framework of the IIA, and with the IIA Code of Ethics, which is a statement of  principles and expectations governing behaviour of individuals and organisations in  the conduct of internal auditing. These principles and behaviours include integrity,  objectivity, confidentiality, and competency.  Internal Audit reports directly to the Governing Body (Audit Committee).  To support statutory auditors in auditing the wider corporate information, we believe  there should be an important and enhanced role for the work of Internal Audit.   To support statutory auditors having a better understanding of the company's broader  financial and non-financial risk landscape, the Chief Internal Auditor and the partner  responsible for the external audit, should ensure appropriate and regular  communication and sharing of information.   In order to maintain both assurance functions' independence and objectivity, whilst  external/statutory audit cannot receive direct assistance and cannot rely wholly on  the work of Internal Audit, and vice versa (in accordance with our respective  professional standards), statutory auditors should make appropriate use of Internal  Audit reports, to place maximum reliance of the work performed and the related  findings, also to get a better sense of a company's approach to key risk areas (e.g.  ESG corporate culture, ..), whilst maintaining professional scepticism.   As some areas might be \"non auditable\" because of the lack of standards, lack of  data (mainly the soft(er) aspects of the information), it would be useful to define the  level of assurance required. Maybe internal auditors are best placed to report on  these elements (e.g.: diversity and equality, behavioural board culture,…) in their  \"insight\" role.  The collaboration should be validated by the Governing Body and be explicitly  published in the governance disclosure."]
["Survey","ECIIA","Other - please specify (required)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree",null,null,null,""]
["Survey","ECIIA","Other - please specify (required)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree"]
["Survey","GIST Impact","User (analyst, data provider, rating agency, etc.)","Switzerland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","GIST Impact","User (analyst, data provider, rating agency, etc.)","Switzerland","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I agree"]
["Survey","GIST Impact","User (analyst, data provider, rating agency, etc.)","Switzerland","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","GIST Impact","User (analyst, data provider, rating agency, etc.)","Switzerland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","Here EFRAG should release additional guidance on non-EU adequate wages in ESRS S1"]
["Survey","GIST Impact","User (analyst, data provider, rating agency, etc.)","Switzerland","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","PwC International Limited","Auditor","United Kingdom","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","We believe the new guidance on how to consider remediation, mitigation, and prevention actions related to impacts in the DMA is helpful for preparers. We believe that EFRAG should provide complimentary guidance on how to assess remediation, mitigation, and prevention actions for sustainability related risks.   The guidance is not clear on how an entity should consider its policies in its double materiality assessment. ESRS 1 paragraph 35 states that when supportable evidence exists related to mitigation or prevention actions, an entity is allowed to reduce the severity or likelihood for potential impacts. However, if significant ongoing action is required, then those mitigation or prevention actions cannot be considered. There is a tension between these two statements. For example, if an entity requires employees to sign annual certifications related to understanding and compliance with ethical policies and there is no history of non-compliance, it is unclear on how to assess this information in the materiality assessment. We believe additional guidance as to what constitutes \"significant ongoing action\" would be helpful. PwC's Sustainability reporting guide section 4.3.2.5 provides our view on areas an entity may need to understand when determining whether a previous action relies on \"significant ongoing action\" to reduce the severity or likelihood of a potential impact.   Additionally, ESRS 1 AR 12 discusses policies and implies that if policies are implemented, the policies may be considered in the materiality assessment. Consistent with the point above and the AR \"policies are implemented through actions\", so the relationship between implemented policies and ongoing actions needs to be clarified.   We have separately provided our detailed comments on ESRS 1 Appendix C on potential impacts (see Appendix D). We believe that in some cases the treatment of the scenarios in the appendix are inconsistent with our understanding of ESRS 1 paragraphs 34 and 35."]
["Survey","PwC International Limited","Auditor","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Broadly, we agree the reliefs provided in Amended ESRS 1 will be beneficial to preparers without reducing the usefulness of the sustainability reporting, with the exception of ESRS 1 paragraphs 91 and 92 which are discussed in questions 18 and 15, respectively.    We support the inclusion of the concept of the use of reasonable and supportable information without undue cost or effort. This is a foundational concept used throughout corporate reporting, including within both the IFRS Accounting Standards and the IFRS Sustainability Reporting Standards. Its inclusion within ESRS would support connectivity with the financial statements and interoperability with the ISSB standards. We believe, however, that the principle of undue cost or effort is a general principle that should be expanded to apply across all aspects of reporting in accordance with ESRS. This would ease the reporting burden for preparers and recognise the evolving landscape of sustainability reporting, including the lack of availability of data in certain areas.    ESRS 1 paragraph 87 appears to limit this principle to the list of areas provided. We believe that this paragraph should clarify that it is intended to provide a list of illustrative examples. Further, we believe that when an entity has omitted information from its sustainability statement due to the application of this principle, the entity should provide additional disclosures to provide transparency and relevant information to users (see Question 18).     In addition, we believe the last sentence in ESRS 1 AR 24 should be deleted. We believe the requirement for an entity to provide information about only the activities that are relevant to the IRO is covered by ESRS 1 paragraph 90. ESRS 1 AR 24 is linked to the aggregation and disaggregation of information, and we do not believe this sentence is relevant to those concepts."]
["Survey","PwC International Limited","Auditor","United Kingdom","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","We support the incorporation of fair presentation in Amended ESRS 1 as we believe it would provide more meaningful information to stakeholders and a potentially more complete view of an entity's impacts, risks, and opportunities. In addition, specifying that this is a fair presentation framework would enhance alignment with both the IFRS Sustainability Disclosure Standards—which are a fair presentation framework—and financial reporting. It is important to note, however, that we do not believe fair presentation will necessarily result in a reduction in the number of datapoints or further ease the reporting burden.   An important concept in achieving fair presentation, however, is management's responsibility for the fair presentation of the information presented. We believe EFRAG should include a specific requirement to disclose that the statement has been prepared on a fair presentation basis in ESRS 2 BP-1.   We also recommend certain changes to the proposed requirements to improve the operability of fair presentation and support the objectives of high-quality reporting. Specifically, we believe that the wording should be clearer in terms of what 'fair presentation' means and recommend that EFRAG incorporate additional wording from IFRS S1 paragraphs 11 to 16. For example, IFRS S1 paragraph 15(b) specifies that a fair presentation may require disclosures beyond the standards (that is, entity specific disclosures). This language clarifies the role of entity specific disclosures in a fair presentation framework. Further, although we support the provisions which would allow an entity to omit a disclosure when reasonable and supportable information is not available without undue cost or effort, we believe the current relief may provide flexibility that could result in conflict with a fair presentation. We believe additional disclosures should be required when this relief is applied to provide more transparency to users about the omitted information (see Question 18)."]
["Survey","Fortum Oyj","Preparer (non-financial preparing a sustainability report)","Finland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Fortum supports the proposed changes."]
["Survey","Fortum Oyj","Preparer (non-financial preparing a sustainability report)","Finland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","EFRAG has clearly considered in detail the interoperability between the ESRS and IFRS standards. While numerous adjustments have been made to enhance alignment, notable differences still remain. It would be beneficial for all stakeholders if these remaining gaps were addressed. At least, even if full interoperability would not be reached, the ESRS should be designed in such a way that companies adhering to them would not need to consider additional data points when also reporting under IFRS."]
["Survey","Fortum Oyj","Preparer (non-financial preparing a sustainability report)","Finland","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","We support reporting requirements that are in line with the Pay Transparency Directive."]
["Survey","Fortum Oyj","Preparer (non-financial preparing a sustainability report)","Finland","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Fortum Oyj","Preparer (non-financial preparing a sustainability report)","Finland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey",".","Consultant (including software vendor)","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","I find the separation between GDRs (ESRS 2) and the topical standards challenging. The topical standards refer directly to ESRS 2. However, it would be preferable to report directly on the IROs and the relevant GDRs within the topical standards. ESRS 2 should only cover general matters, not the topics of individual standards."]
["Survey",".","Consultant (including software vendor)","Germany","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","From a critical perspective, the arguments for an exception for financial institutions appear weak. While estimating absolute targets may involve assumptions, such complexity is common across all sectors. Omitting absolute targets risks masking the total climate impact and undermines transparency. Moreover, granting an exception could create an uneven playing field and reduce comparability between sectors. Overall, both intensity and absolute targets are necessary for a meaningful assessment of progress."]
["Survey",".","Consultant (including software vendor)","Germany","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","DR 4-1: I believe the Transition plan for biodiversity and ecosystems should be made mandatory to help keep the already exceeded planetary boundaries in check and to protect biodiversity and ecosystems."]
["Survey","International Transport Workers' Federation","Trade union","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Double materiality is essential and must remain at the heart of the ESRS framework and European Union sustainability regime for corporate reporting to be credible and useful. Lobbying of EU institutions by US-based standard setters and asset managers should not be allowed to undermine this principle and further water down corporate accountability for significant environment and social impacts, including breaches of fundamental labour rights. Over this year, the process to identify material issues using the ESRS and the first reports prepared until the Corporate Sustainability Reporting Directive (CSRD) have provided an important basis to engage with multinational businesses so that they better understand and address the very real risks and impacts in relation to their own workforce and workers in the value chain.  The principle of \"materiality of information\" is concerning since it introduces a further filter for companies to not report information. For example, it represents a step backwards from ID-177, which says that most S1 metrics must be reported if S1 Own Workforce is material. It is essential to maintain the principle of fair presentation in the reporting standards.  It is positive that the revision of the AR 16 list of topics has maintained all of the sub-subtopics for S1 + S2. These are based on the list of social topics in the CSRD and should all be maintained. The emphasis on aggregation (as opposed to disaggregation) is concerning, as disaggregated information (both site-specific and country-specific) is key to understanding the distribution of impacts, risks and opportunities."]
["Survey","International Transport Workers' Federation","Trade union","United Kingdom","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","It is concerning that mandatory guidance in the Set 1 ESRS has been downgraded to \"non-mandatory\". Mandatory guidance is key to ensuring comparability and completeness of sustainability reporting. At a minimum, Non-mandatory Implementation Guidance (NMIG) should be included in the Delegated Act, and ideally called Mandatory Implementation Guidance.    A major point of concern is that ID-177, which provided guidance that most S1 metrics should be reported if S1 Own Workforce is material, has now been downgraded into NMIG. Instead, EFRAG should preserve and promote the guidance that at the very least most S1 metrics shall be reported."]
["Survey","International Transport Workers' Federation","Trade union","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Adding a datapoint on training of the procurement team is needed to support the implementation of human rights in the supply chain. The addition of a datapoint on confirmed incidents of bribery is needed to improve transparency on the effectiveness of bribery/corruption policies and measures."]
["Survey","International Transport Workers' Federation","Trade union","United Kingdom","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","The \"top 10\" threshold for reporting country-level data on employment, collective bargaining and social dialogue is a major improvement over the current 10% employment threshold. An analysis of the first sustainability statements from Wave 1 companies shows that the current 10% threshold results in country-level disclosures on as little as 21% of total employees. More country-level information is needed to understand the distribution of impacts across countries, as well as whether employment thresholds for specific labour rights have been exceeded.  The new threshold does not require additional effort/cost by companies, since they must gather country-level data anyways to calculate the global figures. Furthermore, it does not result in extra datapoints, since the information currently is (and can be under the revised ESRS) reported as one table."]
["Survey","International Transport Workers' Federation","Trade union","United Kingdom","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The definition of own workforce should be expanded to include franchise workers. The term \"non-employees\" should be supplemented with the phrase \"non-employee workers\" or \"non-employee workers in own workforce\"."]
["Survey","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","Option 2 is too limited with qualitative data with no commitments. Regarding option 1, it should be amended and simplified : c iii is not clear and should be deleted"]
["Survey","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","GIFAS is supportive of this proposal because  it is often very difficult for companies, to obtain even estimates on assets operated by third-party companies, for example. Even if companies implement improvement processes, it is not always certain that reliable data can be obtained at a later date, particularly when third parties operate in jurisdictions that are not subject to ESRS. We also agree that no time limit should be imposed since as mentioned in the basis for conclusion, transparency about such limitation would provide sufficient incentive for the undertaking to improve the data quality and achieve a more complete scope in the calculation of the metrics."]
["Survey","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","GIFAS members do not support introduction of \"fair presentation\" in the ESRS. EFRAG's rationale being to allow companies to focus on essential information and to avoid a compliance approach ; to enhance interoperability. Since the mandate given by the Commission is to reduce and streamline, new concept should not be introduced in the ESRS, especially when not clear.  Fair presentation is a new concept not used in the Accounting Directive which only refers to \"true and fair view\" regarding financial statements.  French and European stakeholders have diverging interpretations of potential impacts and consequences : for some key stakeholders, it means the addition of supplementary datapoints in the report and it increases liability for both preparers and auditors to reach completeness, thus not reducing the reporting burden. French auditors consider that they will have to perform more due diligences and that the audit burden will be increased. Regarding liability, companies highlights that consequences are different in a double materiality reporting framework than in a financial one given the number of affected stakeholders, the importance of narrative and forward-looking information required by the ESRS. EFRAG is trying to frame the double materiality assessment, stating that undertakings are not required to assess every possible IROs but this provision is not sufficient in case of litigation.  As regards interoperability with the IFRS, the ISSB claims a level of interoperability of 95% regarding climate reporting. The remaining 5% are rather technical and clearly identified; they can be addressed directly without introducing fair presentation."]
["Survey","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","GIFAS members welcome the intention to provide guidance for companies in setting biodiversity targets, provided that the future application guidance remains voluntary and is integrated into the NMIG."]
["Survey","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"ESRS E1:   −\tE1-1/E1-6: GIFAS members remind that the EC committed to define by end of 2025 the meaning of \"compatibility between companies' target and 1.5°C targets\". Until such a definition is published, no obligations are legitimate on this issue. Moreover the Paris Agreement also refers to \"well below 2°C objective\" which should be reinserted in the amended CSRD.  −\tCompanies consider, in the case where disclosing an absolute emissions target would provide to competitors key sensitive information (i.e.: production forecasts) which are very sensitive, that they should be entitled to publish only a target expressed in intensity,. In this regard, a clarification that the \"relief\" mentioned in ESRS 1 §98 is effectively applicable for section E1-6 appears essential.  −\tE1-3: The notion of resilience used in this section is very much unclear (see glossary); if the concept refers to adaptation, then it should be replaced by climate adaptation (without any reference to transition)  −\tE1-6/E1-8: The distinction between financial control and operational control remains insufficiently clear, and it is uncertain whether the current drafting produces a positive outcome for preparers. This lack of clarity risks confusion in the interpretation of scope 1 and 2 emissions  −\tE1-5/E1-9 : some obligations have been added (§24 a ; §24c ; § 34) and should be suppressed.   ESRS E2: Requiring undertakings to disclose information on substances of concern goes beyond the obligations set by REACH and creates a significant additional burden. The same remark applies to the 0.1% threshold mentioned for disclosures relating to the quantities of SVHC which are part of procured/sold components or articles. Indeed, REACH only requires companies to share the name of those substances. Therefore, reporting on substances of concern should be suppressed, as proposed by the French Accounting Standards Authority, and datapoints 20(a) and 20(b) amended accordingly."]
["Survey","Związek Banków Polskich","Association of financial institutions","Poland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Our main concerns are regarding the \"undue cost or effort\", there is lack of a clear objective definition for \"disproportionality\". What is a standard cost for a large multinational corporation may represent a significant burden for SME. The lack of specific criteria (e.g. financial thresholds, number of working hours) means that each company will have to assess independently whether a given cost is \"proportional\". This could lead to highly varied approaches to the same issue. This will cause problems for auditors and problems with comparability of reporting. It may also cause risk of abuses and \"selective reporting\"  This principle provides companies with opportunity to omit certain, uncomfortable disclosures. In our opinion, a safe harbor for portfolio estimates (Scope 3.15) is needed. This can be achieved, for example, by establishing protection for 2-3 disclosure cycles by demonstrating \"best effort\" estimates, provided the bank discloses the method, sources, and improvement plan."]
["Survey","Związek Banków Polskich","Association of financial institutions","Poland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","While we strongly support efforts to strengthen appropriate remuneration disclosure, the current approach introduces ambiguity and complexity. Clear guidelines and flexibility are needed to ensure consistent, transparent, and decision-relevant reporting."]
["Survey","Aquaculture Stewardship Council","NGO","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","Striking the balance between \"a) stakeholders' demands for burden reliefs and (b) preserving the transparency\" should however weigh favourably towards transparency; and for any disclosure/reporting claim to be credible, these disclosures should be based on quality & direct data/metrics. The amendments proposed favour too much/too many horizontal reliefs in our views."]
["Survey","Aquaculture Stewardship Council","NGO","Netherlands","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","Aquaculture Stewardship Council","NGO","Netherlands","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Finance for Biodiversity Foundation","Association of financial institutions","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Any remaining lack of clarity constitutes a risk as it may result in varying negative impacts not being reported as material, and therefore irregular reporting that cannot be compared across assessments.   Notably, comparability can be lost under the notion of \"significant action\", not being precisely defined and thus subject to diverse interpretation.   Requiring disclosure of potential and actual impacts based solely on pre-mitigation assessment would discourage effective risk management by overlooking meaningful actions already taken. However, judgments about remediation and prevention can vary significantly without established baselines and guidelines. This can then affect the values and data reported. Negative and positive impacts should always be reported separately, as recommended by the Partnership on Biodiversity Accounting Financials (PBAF).   Primary and secondary data should both be collected to improve the accuracy of reporting and include datapoints of location and attribution. When considering reporting on impacts over a financial year, remedial activities contributing to the reduction of actual impacts should be considered, along with long-term expected effects on potential impacts.    Finally, the FfB Foundation supports reporting on both actual and potential impacts, as each category provides information that are decision-useful to businesses and investors."]
["Survey","Finance for Biodiversity Foundation","Association of financial institutions","Netherlands","35.E4-3."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","In reference to question 14 (standards' architecture) and to question 30 of the survey (biodiversity targets), the actions and resources related to biodiversity and ecosystems should not be only about the conservation and restoration of nature, but also about the reduction of pressures that are the sources of impacts on biodiversity. Furthermore, considering that targets are not mandatory (ESRS 2, 44), we suggest for the free, prior, and informed consents of Indigenous People and Local Communities to also be mentioned in actions and resources.","E4","Disclosure Requirement E4-3 - Actions and resources related to biodiversity and ecosystems",""]
["Survey","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I agree"]
["Survey","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium","22.S1","Comments on deleted datapoints in ESRS S1","I disagree","We appreciate the deletion and movement of certain requirements from mandatory to non-mandatory, particularly the improved layout and the placement of Application Requirements directly under the related Disclosure Requirements. This reduces the need for cross-referencing and makes the standards more user-friendly. Nevertheless, the simplification is primarily structural. It improves navigation but does not lessen the overall reporting burden, as the workload required for compliance remains unchanged."]
["Survey","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium","22.S2","Comments on deleted datapoints in ESRS S2","I disagree","We appreciate the deletion and movement of certain requirements from mandatory to non-mandatory, particularly the improved layout and the placement of Application Requirements directly under the related Disclosure Requirements. This reduces the need for cross-referencing and makes the standards more user-friendly. Nevertheless, the simplification is primarily structural. It improves navigation but does not lessen the overall reporting burden, as the workload required for compliance remains unchanged."]
["Survey","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","Disclosing the total weight of SoCs/SVHCs, especially in mixtures, is a complex and burdensome process that doesn't help demonstrate if a company sustainably uses these substances. In addition, reporting SoCs/SVHCs in hazard class can lead to double-counting. A more qualitative approach is desired.  ESRS shall avoid double reporting and overlap/inconsistency with obligations stemming from existing environmental legislation, as requested by the EU Commission in their mandate for revised ESRS. To ensure coherence, the ESRS mustn't introduce costly pollutant reporting obligations that would conflict with or duplicate those under the Industrial Emissions Directive (IED). Companies in the scope of the IED shall directly refer to quantities of pollutants as reported under Regulation (EU) 2024/1244 (Industrial Emissions Portal Regulation). This would ensure legal consistency, avoid regulatory overlap and reduce the reporting burden. The IED and underlying BREF documents are the sector-specific legal framework governing pollutant emissions, including thresholds, frequency, and reporting validation. Data collected under the IED (e.g., pollutant releases to air, water, and land; off-site waste transfers) forms the basis for E-PRTR data reporting. The monitoring of all relevant sources of emissions, including measurement methodology, frequency, evaluation procedure and reporting, is defined in detail in the environmental permit of IED installations. There is no need for additional pollutants or requirements.  In addition, an assumed direct link between SOCs/SVHCs and sustainable use is fundamentally flawed. In the case of metals and their compounds, for example, such substances are responsibly sourced and processed under permit within IED BREF requirements, safely used in the EU market as detailed in REACH dossiers, respecting restrictions and other risk-management options, and are sustainably recyclable at the end of life. On the contrary, contrast this with a non-hazardous substance, which may be a fossil-fuel-based chemical, with dispersive use and not recycled. Which is the more sustainable business model?"]
["Survey","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The glossary hasn't been updated to match the new requirements."]
["Survey","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Additional comments are added in the specific sections in the Excel."]
["Survey","Nokia","Preparer (non-financial preparing a sustainability report)","Finland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","Comments are provided for some of the respective datapoints, specifically ESRS G1."]
["Survey","Nokia","Preparer (non-financial preparing a sustainability report)","Finland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Nokia","Preparer (non-financial preparing a sustainability report)","Finland","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The text is simplified and more understandable but further clarifications and modifications are needed (see comments)."]
["Survey","UPM-Kymmene Corporation","Preparer (non-financial preparing a sustainability report)","Finland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","UPM-Kymmene Corporation","Preparer (non-financial preparing a sustainability report)","Finland","35.ESRS1_7.8."," Do you agree with the amendments of this chapter? ","I disagree","Reasons for omissions are very limited based on this DR. There can be commercially-sensitive information which is neither  covered by the §100 and its references to EU legislation for the definition of classified and sensitive information nor by §99 which only covers information about strategy and action plans. Organisations should not be forced to disclose commercially-sensitive information which can have an influence on their competitiveness. Please consider to amend this DR to widen the scope of §99 beyond information related to strategy and action plans.","ESRS1","7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation",""]
["Survey","Tata Consulting Services","Other - please specify (required)","India","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Tata Consulting Services","Other - please specify (required)","India","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I disagree","As a company based in Mumbai, serving clients around the world, we are obligated to report using ESRS but IFRS is not of particular interest. Only a minority of countries are adopting IFRS at this point, larger markets such as the US and India are not. India has its own standard, BRSR. We believe that interoperability with 'global standards' should be looked at more broadly. SASB is not a global standard--and was designed solely for by use by investors. We believe the recommendation to use SASB should be replaced with a recommendation to use GRI sector standards."]
["Survey","Tata Consulting Services","Other - please specify (required)","India","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Tata Consulting Services","Other - please specify (required)","India","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Tata Consulting Services","Other - please specify (required)","India","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"One consequence of the 'simplification' drive is that the pathway to reasonable assurance has ended. We applaud the superb job EFRAG has done in a very short time period to refine ESRS, and it is understandable that most of the focus has been on the datapoints--what is reported. However, we feel that there should also be consideration of the quality of what is reported. EFRAG is in a position to provide nudges toward better quality data--even if reasonable assurance will not be mandated by the EU in the foreseeable future. The history of GRI offers many examples of distinguishing between different levels of reporting completeness and assurance, and it would be great if EFRAG could use these for inspiration. For instance, at one point GRI gave reporters the options of declaring that their reporting was A, B or C level and that, for those with assurance, they could declare a report was A+ or B+. The journey to reasonable assurance is time consuming and expensive--but aligning the quality of sustainability data with financial data is a worthwhile investment for companies and for society. We believe that EFRAG should be offering companies a tangible way of acknowledging high quality data--with reasonable assurance. Of our client base, many wave 1 reporters have already made investments in this area. EFRAG should look to support the continuation of this work."]
["Survey","European Contact Group","Auditor","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","We propose to include an impracticability exception for specific data points in limited situations when a company is not able to provide a metric after making reasonable effort. Such exception could be limited in time (like the existing ESRS 1 relief for the 'value chain' data points) or permanent. We suggest replacing the current text with a wording aligned with the definition in IFRS S1 which states that \"applying a requirement is impracticable when the entity cannot apply it after making every reasonable effort to do so\". We suggest that EFRAG reflects on this – also in light of maturity of companies and methodologies – as part of a future post-implementation review of ESRS."]
["Survey","European Contact Group","Auditor","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","We welcome EFRAG providing clarity around the question of ESRS being a fair presentation versus a compliance framework. It is of utmost importance that all qualitative characteristics of a fair presentation framework are included in the final revised ESRS, ideally fully aligned with the guidance in the IFRS Standards to ensure interoperability, including linking to entity-specific information (which now has more prominence given the reduction in mandatory datapoints and the ceased mandate for EFRAG to develop sector standards). This would also include a statement on the basis for preparation that the sustainability statement is prepared on a fair presentation basis. This would also make clear the roles and responsibilities of those involved in the reporting process, reduces diversity and, hence, avoid frustration in the corporate reporting ecosystem. We also believe that the commonalities and differences between the two concepts are sometimes not well understood in practice and might lead to misconceptions, particularly the idea that fair presentation is 'less than compliance'. Hence, we suggest adding some educational language in the NMIG or Basis for Conclusions to inform stakeholders or complement the main body of ESRS 1 if needed. While outside EFRAG's mandate, we note that the foundation for fair presentation should be clearly established in the CSRD as the legislative basis for ESRS."]
["Survey","Dutch Accounting Standards Board","(National) standard setter","Netherlands","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Proposed amendment 7 (relief for acquisitions or disposals) results in challenges e.g. on data availability, such as the inclusion of a business' carbon emissions from Jan - Sept if this business is sold in October. We suggest adding practical examples.   We suggest to make the relief included for acquisitions conditional on the undue cost or effort; based on facts and circumstances such relief could be applied for the acquisition as a whole or for certain specific information depending on the undue-cost-and-effort-principle.  The relief provided for disposals might lead to important information not being reported on even when that information is available. DASB suggests that material IROs and data related to disposed activities during the reporting period shall not be excluded from material IROs of the group in that reporting year and only to exclude them based on the principle of undue cost or effort. Some impacts/risks might still be relevant to report beyond the date of disposal. E.g. in case of potential liabilities related to soil pollution this might lead to significant anticipated financial effects for the undertaking itself. We welcome additional NMIG guidance hereon. We suggest transparency on disposed activities by separating the presentation of data/metrics related to material \"disposed activities\" and the data relating to continuing operations. We refer to current principles in IFRS 5 for financial statements as inspiration for this approach.  Disclosures are required for major transactions or significant events occurring between acquisition or disposal date and the end/beginning of the reporting period. This doesn't seem to include the IROs at acquisition date related to the subsidiary. When acquiring a new subsidiary with other material IROs than the group, additional transparency might be needed to ensure a fair presentation of IROs.  EFRAG could include DRs similar to the DRs in BP-2 for undertakings that use phase-ins."]
["Survey","Dutch Accounting Standards Board","(National) standard setter","Netherlands","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","The DASB agrees that these exceptions to the general rule are appropriate and justified"]
["Survey","Dutch Accounting Standards Board","(National) standard setter","Netherlands","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","The DASB questions whethter the intended purpose of the DR (in short protection of SMEs) will be achieved in practice. We expect that late payments in practice result in legal proceedings which might have the late payment as base, but mostly result in discussions on the absence of full delivery of the product.   Is the annual report and transperancy (given the historic character) the most appropriate place and resource to stimulate fair payment practices for SMEs? Shouldn't the information on payments be easily accessible for SMEs e.g. on the website as part of the generals terms and conditions?  However, the DR could be used as a tool for auditors to, for example, share sector information with undertakings on payment practices.   We believe the current replacement formulation is sufficient."]
["Survey","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","AFME supports the horizontal reliefs proposed in the revised ESRS, including the IFRS 'undue cost or effort' relief (#1). From our members' experience with this relief in the context of financial reporting, this is still a high bar to meet in the context of the audit which could lead to multiple interpretations in the context of impact materiality. EFRAG should clarify that management has sufficient flexibility to determine \"undue cost and effort\" with respect to each entity in scope, and the meaning of this relief should also be informed by the value chain cap. EFRAG should clarify that companies subject to the CSRD have no obligation to collect non-publicly available data from companies not subject to the CSRD or have no obligation to estimate this information to close data gaps.  We also support #3 which allows the use of proxies/estimates where appropriate. Reporting entities, especially financial institutions, face ongoing challenges in accessing high-quality Scope 3 emissions data. For global financial institutions, much of this data comes from counterparties in jurisdictions without sustainability reporting mandates, leading to inconsistent, incomplete, or delayed data—often lagging by 12 to 18 months. However, members highlight that proxies are not an automatic solution to data delays and data gaps. Proxies and estimates must still come from reputable third-party providers and be based upon a standardised methodology to provide the required level of transparency."]
["Survey","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","No, EFRAG should not review AR26 for the Amended ESRS E4. The existing ESRS 2 GDR-T provides comprehensive guidance for target-setting disclosures, and additional prescriptive application requirements would create implementation complexity without proportional benefits."]
["Survey","WWF EPO ","NGO","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","The proposed changes are meaningful and welcomed as a whole.    However, we would like to highlight that Taxonomy-related information should be visible and easily available in the reporting. This information is far too important to be given reduced visibility —particularly given its critical role in securing capital and financing, enhancing corporate valuation, and demonstrating effective risk management and strategic planning, and while analytical reports are gradually evidencing that the EU taxonomy framework is useful for financing the sustainable transition of EU companies.   For example, mortgages and other loans linked to Taxonomy-eligible activities account for, on average, more than 50% of large EU banks' assets, based on first-year reporting data. In our experience, major users of sustainability information—especially financial institutions—actively seek out this data as a priority. Placing it in an appendix risks reducing its visibility, leading to fragmentation and hindering the usability and comparability of disclosures.   Moreover, it's worth noting that more than 50 countries globally have already established their own taxonomy frameworks, and capital flows into Taxonomy-aligned activities in the EU witnessed a grow last year—even amid a broader political push for regulatory simplification. This demonstrates the enduring economic and strategic relevance of clear, accessible Taxonomy reporting.   Relevant Sources: https://finance.ec.europa.eu/document/download/08dd5091-6df7-45ed-8dc1-2583007594c4_en?filename=240605-sustainable-finance-taxonomy-factsheet_en.pdf"]
["Survey","WWF EPO ","NGO","Belgium","22.E2.","Comments on deleted datapoints in ESRS E2","I partially agree and partially disagree","As an organization mostly focused on nature, biodiversity and climate related issues, the deletion of several datapoints and wording under E2, E3 and E4 is of very high concern to us. This was already highlighted in the question related to \"may\" statements. Specific issues will be developed in the relevant sections of this questionnaire."]
["Survey","WWF EPO ","NGO","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","We agree that AR 26 should be reviewed to ensure alignment with leading global frameworks on biodiversity and ecosystem-related target setting. The current wording does not provide sufficient clarity or specificity regarding how companies should define, measure, and disclose biodiversity-related targets. Strengthening the guidance in AR 26 would support greater consistency and comparability in disclosures, while anchoring the standard in established, science-based methodologies. The following frameworks should be considered :    -The Science Based Targets Network (SBTN), particularly Step 3 – 'Measure, Set & Disclose Targets' of the SBTN corporate guidance;   -The Taskforce on Nature-related Financial Disclosures (TNFD), including components P1 and P2 of the LEAP approach, Annex 5 on target-setting;   -Resources from the World Economic Forum on Nature-Positive Transitions, which provide sector-specific pathways and metrics to support nature-positive business strategies   -WWF report on Nature Transition Plans"]
["Survey","WWF EPO ","NGO","Belgium","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","We are particularly concerned over the deletion of the Application requirement specific to water risk areas/high water stress areas. Further, there is very little reference to marine resources, only specified in the objectives and \"interactions with other ESRS\"."]
["Survey","WWF EPO ","NGO","Belgium","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Group Caisse des Dépôts","Asset manager/Investor","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I would like to skip this question and provide my feedback in Part 3",null,null,null,""]
["Survey","Group Caisse des Dépôts","Asset manager/Investor","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)","Overall, the simplification is targeting redundant datapoints or datapoints that do not impact the overall ambition.  However, some deleted content should be maintained, in particular: -\tESRS 2: The normalized revenue breakdown by sectors  -\tESRS 2: the share of climate criteria in the incentive's schemes (in a simplified manner embedded in the existing ESG criteria to reduce the actual complexity but provide a key information for investors on climate governance).  -\tESRS 2: Number of executive members -\tESRS E1: The suppression of the template for Gross GHG emissions and the standardized presentation of the Ghg reduction target reduces comparability for stakeholders using the sustainability statements and should not be maintained. The datapoints that should be maintained correspond to the need of interoperability with international frameworks and investors' needs.  Moreover, the Caisse des Dépôts Group believes that EFRAG's proposal corresponds to the maximum data-reduction achievable, below which the objective of the original CSRD would be endangered. In particular, the transparency of the compatibility of the transition plan with 1.5°C ambition should be maintained."]
["Survey","Group Caisse des Dépôts","Asset manager/Investor","France","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree","We support the overall efforts to simplify the standards while maintaining datapoints investors need to calculate SFDR Principal Adverse Impact (PAI) indicators. Ensuring this alignment between revised ESRS and future SFDR should be key."]
["Survey","Group Caisse des Dépôts","Asset manager/Investor","France","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","ESRS E2:  •\tThe suppression of the disclosure on \"the policies in place to manage material IROs related to pollution\" (the proposition to refer to the NMIG) is not appropriate considering a) the impacts of the widespread pollution and its consequences on human health as well as on biodiversity and ecosystems; b) reputational and transition risks; c) opportunities on clean up or decontamination activities. •\tTo allow users to provide comments and therefore help undertakings to improve their future sustainability statements, EFRAG could add a provision in ESRS 2 SBM-2 (interest and views of stakeholders) requiring undertakings to disclose \"whether and how the administrative, management and supervisory bodies are informed about remarks from users relating to pervious sustainability statements\""]
["Survey","Group Caisse des Dépôts","Asset manager/Investor","France","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","FPS Health, Food Chain Safety & Environment (SPF-SPSCAE-DGEM)","Other - please specify (required)","Belgium","35.E1-6."," Do you agree with the amendments of this chapter? ","I agree","DG environment of the Federal Public Services Health, Food Chain Safety & Environment is not in favor of the exemption for banks on absolute targets settings for the reasons outlined below:  Absolute emissions targets are a critical component of credible climate strategies, including within the banking sector. Their relevance is underscored by several key factors: •\tThey demand real emissions reductions, regardless of business growth or changes in operational scale. •\tThey offer clarity and measurability, enabling straightforward tracking of progress: a decrease in emissions is immediately visible. •\tThey align with climate science, particularly with the objectives of the Paris Agreement, such as limiting global warming to 1.5°C. In contrast, relying solely on emissions intensity (e.g., emissions per euro invested or per unit of revenue) can be misleading. Intensity may improve while total emissions continue to rise, especially in cases of portfolio or business growth. Therefore, both absolute and intensity-based metrics are necessary to fully understand the implications of a bank's climate strategy. However, absolute targets are especially relevant when a bank adopts a divestment approach, as they directly reflect the reduction in exposure to high-emission sectors","E1","Disclosure Requirement E1-6 - Targets related to climate change",""]
["Survey","Grant Thornton International Ltd","Auditor","United Kingdom","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We support option 1, with the aim to strengthen interoperability with ISSB Standards. We recognise the importance of anticipated financial effects for users of the sustainability reports, however quantification remains challenging in the first years of reporting. Therefore, a phased-in relief is appropriate and should avoid unreliable figures being reported.   We consider that option 2 would drop below the ISSB global baseline requirements and therefore we would not support this option."]
["Survey","Grant Thornton International Ltd","Auditor","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Grant Thornton International Ltd","Auditor","United Kingdom","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","In general, we agree with the approach to remove voluntary datapoints to simplify and streamline disclosures. However, in this case 'adjusted gender pay gap' could be considered material information for any organisations that are reporting on gender pay gap. We also note that this is an area that should align with the EU Pay Transparency Directive. The data should already be available for reporting entities in scope so it is not clear why they should not disclose it. Additionally, we suggest emphasising that the methodology for calculating the adjusted gender pay gap should be aligned with the implementation guidance published (or will be published in the future) in the context of the EU Pay Transparency Directive."]
["Survey","Climate & Company – The Berlin Institute for Climate Training and Research gGmbH","NGO","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","Executive Summary: We do not consider it necessary to introduce a formal requirement or option for an \"executive summary\" within the sustainability statement. Companies already have the flexibility to provide introductory material to their reporting, and many do so in the context of their financial reports. The proposed addition would therefore not add substantive value, while creating risks in terms of comparability, auditability and integrity of the reporting framework executive summary, if left unstructured or unaudited, could facilitate selective framing and undermine trust in sustainability reporting. Readers may rely on such a summary rather than on the actual ESRS disclosures, which risks distorting the purpose of the standards. From a transparency perspective, it is essential that any communication provided under the ESRS framework is directly traceable to the underlying disclosures. If EFRAG maintains the option, it is crucial to establish clear safeguards: the executive summary must not contain information beyond the ESRS content, must be explicitly linked back to the corresponding disclosures, and must fall within the scope of assurance. Without these safeguards, the introduction of an executive summary risks weakening the credibility and comparability of sustainability reporting. Appendices: We could envision a role for appendices as a structured place to store detailed metrics, EU Taxonomy disclosures, and potentially also voluntary information on non-material issues. This could improve readability for some users by keeping the main report more concise, while still ensuring full transparency. At the same time, care is needed: separating information across main reports and appendices may complicate auditability, reduce comparability, and risk frustrating professional users who need complete data in one place. If pursued, the approach should be tested carefully to ensure it enhances usability without creating repetition or undermining the integrity of the core disclosures."]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","Although some \"practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported\" have been introduced, it is not clear how these considerations can be applied, given that the entire chapter relating to double materiality retains the current complex and burdensome process. Therefore, it is difficult to evaluate the proposed simplification exercise. A possible solution would be to clarify more precisely the circumstances under which the simplifications can be applied."]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree"]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","We disagree with the introduction of this principle given: \tthe different level of maturity of sustainability reporting compared with financial reporting. The concept of fair presentation is well-established in financial reporting, but not in the context of sustainability reporting—especially considering the double materiality principle, which requires considering a multi-stakeholder approach as opposed to the single/financial materiality perspective. This creates a significant grey area in which the onus is placed on the company to determine what constitutes a fair presentation. \tthe risks associated with this principle in terms of a significant increase in the liabilities of Board members on the one hand and of auditors on the other, who must ensure that the overall set of information provided meets the needs of all categories of users. Under such a regime, companies would not only be required to apply the standards and ensure the consistency of disclosures, but also to demonstrate that the information is fairly presented to all stakeholders. If the fair-presentation requirement were broadly applied to all relevant stakeholders, the scope of information to be disclosed in the sustainability statement could become virtually unlimited, leading in particular to a potentially unchecked expansion of \"entity-specific\" information (i.e. information not sufficiently covered by the standards). \tthe concept, which is clearly stated in the Accounting Directive, is not equally reflected in the CSRD, which requires a compliance-based disclosure framework with regard to the auditing and assurance of sustainability reporting (see, in particular, Article 34(1)(aa)). It would be appropriate to remove all references to fair presentation introduced by EFRAG in ESRS 1 (paragraphs 16, 17, 18), as well as in the other standards, if any, and to clarify that the objective of sustainability reporting is to ensure compliance with the provisions of the CSRD and the ESRS."]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"-"]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","35.S1-13."," Do you agree with the amendments of this chapter? ","I disagree","•\tESRS S1 DR S1-13 Health and safety metrics (paragraph 40): requires information on the percentage of people in the workforce covered by the company's occupational health and safety management systems, the number of work-related fatalities among the company's workforce and among other workers operating at the company's sites, etc. (see Section 3 of the 2025 Amended ESRS Exposure Draft Public Survey by EFRAG). The information required under this DR is overly granular and should be simplified.","S1","Disclosure Requirement S1-13 - Health and Safety metrics",""]
["Survey","UTILITALIA","Business association (other than association of financial institution)","Italy","35.S1-16."," Do you agree with the amendments of this chapter? ","I disagree","•\tESRS S1 DR S1-16 Incidents of discrimination and other human rights incidents (paragraph 46b) requires disclosure of the number of human rights incidents. The term \"severe\" has been removed from the concept of \"human rights incident,\" extending the reporting obligation to any human rights incident and risking the need to carry out very thorough investigations across the value chain, since this term has also been removed from ESRS S2. It would be preferable to reintroduce the concept of \"severe\" and define it more clearly.","S1","Disclosure Requirement S1-16 - Incidents of discrimination and other human rights incidents",""]
["Survey","VBO-FEB","Business association (other than association of financial institution)","Belgium","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets"]
["Survey","German Investment Funds Association BVI","Association of financial institutions","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","To ensure that disclosures on anticipated financial effects are both feasible and effective, we advocate for the consistent application of the \"comply or explain\" principle. This approach should require undertakings to report quantitative information by default. If they are unable to do so (due to unavailability of reasonable data or high uncertainties in anticipation results), undertakings should be required to provide a clear and substantiated explanation. From investors' perspective, such explanation would already provide valuable information, offering insights into a company's risk management maturity and data infrastructure. We expect that the application of the \"comply or explain\" principle will increase adoption rates while simultaneously fostering greater transparency. As collecting and reporting methodologies mature, the ambition of achieving full quantitative disclosure would be maintained, safeguarding that the ESRS remain both deliverable for preparers and decision-useful for investors.",null,null,""]
["Survey","German Investment Funds Association BVI","Association of financial institutions","Germany","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Investors need comparable and consistent sustainability-related data from all their investee companies, inside and outside the EU.  Thus, we support full interoperability between ESRS and IFRS without diluting double materiality and acknowledge EFRAG's efforts made in this regard. We particularly welcome EFRAG's suggestion to include a permanent reference to the IFRS industry-based guidance, including SASB standards, for reporting of entity-specific sectorial information.  Nonetheless, the simplification efforts and the proposed reduction of data points have created new discrepancies, resulting in a situation where the EU reporting standards might lag behind the IFRS requirements. This is particularly evident in the E1 standard, where many detailed disclosures supporting investors' analyses have been deleted. The ESRS will thus not live up to the global baseline meaning that investors will likely receive less information from EU companies than from their non-EU competitors. Ultimately, this loss of transparency might have negative effects on channeling investments to EU transitioning companies.  In order to ensure future-safe interoperability and reduce burden for firms reporting in line with both standards, we strongly suggest introducing a new optionality in the ESRS to report either according to ESRS or IFRS standards for sustainability topics where international standards exist (currently only climate E1-S2, but potentially extending to other topics like human resources or biodiversity in future). This choice should pertain only to the standards for reporting material risks and opportunities, with disclosure of potential impacts being always required in line with the applicable ESRS. This new optionality would allow for providing appropriate relief under the revised ESRS while offering the possibility to live up to the expectations of (international) investors. It would also provide a mechanism that accounts for future evolvement of the international standards and ensures structural interoperability with the ESRS in a pragmatic manner."]
["Survey","ChemSec","NGO","Sweden","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","Quantative information on financial effects is most important for investors to understand the financial risks. Loosing this limits transparency and how these factors impact company performance and risk."]
["Survey","Medtronic","Preparer (non-financial preparing a sustainability report)","United States","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1","As a preparer, I am supportive of EFRAG's recommendation that the Commission not include the Non-Mandatory Illustrative Guidance (NMIG) in the Delegated Act. I think the placement of the NMIG is important – as it should serve as a helpful reference, not as a regulatory requirement. Excluding it from the Delegated Act makes clear to assurance providers that the NMIG is not a mandatory compliance checklist. This distinction helps ensure the NMIG remains useful and flexible for preparers without creating unintended obligations."]
["Survey","Medtronic","Preparer (non-financial preparing a sustainability report)","United States","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","As a preparer, I am strongly supportive of Option 2 which limits disclosure requirements to qualitative information, with voluntary quantitative reporting. I believe qualitative disclosures in this area are more decision-useful for users, primarily for the following reasons:   1)\tSpeculative Nature of Forward-Looking Data: Unlike historical financial data, which is grounded in actual events, disclosures of anticipated financial effects rely heavily on forward-looking assumptions about future climate scenarios, technological advancements, and regulatory changes.  2)\tLack of Comparability for Users: Mandating quantitative disclosures may also undermine comparability across companies."]
["Survey","ETSA ","Business association (other than association of financial institution)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","The provisions for reporting anticipated financial effects have prompted significant discussion. ETSA members support option 1 \"quantitative first\", with multiple provisions: •\tThe focus should be on the quantification of what is material. •\tPreference to limit quantification to material risks, and to allow for estimations of anticipated effects in ranges as (probably) used in the double materiality assessment. Opportunities are harder to quantify and quantification is more likely to contain commercially sensitive information. •\tPreference to limit quantitative disclosures to material physical risks. ETSA members recommend providing relief for material transition risk quantifications by allowing companies to rely on qualitative disclosures."]
["Survey","ETSA ","Business association (other than association of financial institution)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","ETSA members advocate for clear scientific methodologies and sufficient guidance from standard setting bodies on how to develop targets and transition plans for biodiversity impacts.   EFRAG can bring the NMIG on how to set biodiversity-related targets according to the latest trends"]
["Survey","ETSA ","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","EFRAG retains the disclosures on a gender pay gap. ETSA members stress the need to align definitions and reporting on pay gaps with 1) other relevant EU legislation (like the Pay Transparency Directive (EU) 2023/970 and 2) national legislations that require reporting of pay gaps."]
["Survey","Danish Industri","Business association (other than association of financial institution)","Denmark","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","We agree with EFRAG that the NMIG should not be part of the delegated act.  We believe a NMIG-document can provide valuable and helpful information and implementation support, but it needs to be re-written to include other guidance issued by EFRAG (FAQ's, IG1-3). At the same time, the old versions of these documents (FAQ's+IG's) need to be removed as they should be incorporated into the revised ESRS and/or revised illustrative guidance document if still relevant.  The NMIG in the current form is not ready for publication -\tThe current version of the NMIG is a collection of the left-overs of set 1 as indicated in the introduction to the question.  -\tThe NMIG needs to be stripped from \"EFRAG SRB intentions\" as these should be part of the \"Basis for conclusions\" -\tTo the extend the NMIG tries to explain the intention of a definition, clarification of the definition itself may be more relevant. -\tThe illustrative guidance should include more diverse examples (and always minimum 2), to the extent possible based on best practice sustainability statements, illustrating – where relevant – more than one approach to ensure that the intention is conveyed, but without limiting options for the actual reporting. This will strengthen the \"non-binding nature of the document\". We encourage EFRAG to make use of for instance 10 \"standard-companies\" representing different industries and/or complexities in the analysis to ensure a structured variation in the examples and to better tease out the diversity in reporting challenges. This will also alleviate part of the pressure on sector guidance and allow for ongoing additions to the examples, which should be thought into the design.  EFRAG should work on the NMIG after handing in the revised ESRS"]
["Survey","Danish Industri","Business association (other than association of financial institution)","Denmark","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","We believe that the requirement to disaggregate the metrics for characteristics of the undertaking's employees as now suggested to be for the top 10 largest countries with more than 50 employees is too detailed and removes the focus on material and substantial countries. Such a requirement would increase the reporting requirements compared with ESRS Set-1 and thereby contradict the purpose of the Omnibus. Furthermore, it will lead to additional reporting on more details than necessary for a fair presentation, undermining overall relevance.  We suggest that the threshold of 10% is reintroduced or, alternatively, that the minimum number of employees is increased to match the threshold of the entities required to report under the CSRD.   We also note that fair presentation would normally drive reporting at more aggregated levels, for instance regional, to provide more relevant information for the primary user groups and better align with the management approach that should also prevail in S1."]
["Survey","Danish Industri","Business association (other than association of financial institution)","Denmark","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","We Partially Agree.  Adequate wages is mainly a political subject. Therefore, disclosures on wages and wage-setting processes always needs to be seen in a national framework and in context of the national social dialogue. This is vital to ensure that local realities related to the cost of living and economic prospects are fully integrated, therefore the guidance and principles of ILO wage setting processes and principles on estimating a living wage are crucial.  However, we believe that EFRAG and/or the EU-Commission needs to find practical solutions involving for instance databases that the reporting undertakings can rely on to promote comparability and consistency. We note that the OECD in 2023 published a policy insight \"Living wages in practice\" and would encourage EFRAG to invite OECD to provide their advice for a reporting basis that can lead to reliable and comparable principles"]
["Survey","European Committee of Central Balance Sheet Data Offices, ECCBSO (secretariat at Deutsche Bundesbank)","User (analyst, data provider, rating agency, etc.)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","When reviewing the ESRS revision documents, it appears that changes made for \"readability\" purposes primarily serves to the needs of companies in structuring the report. However, the concerns of the report's users, typically being the \"readers\" seem to be addressed only to a small degree. Phrases on important datapoints such as \"users can still derive\" or \"similar information is already disclosed in financial statements\" and the choice to present numerical data in text rather than in tabular format, rather contrast with the readability of sustainability report which stands on its own. Thus, EFRAG might also evaluate these readability aspects when preparing the final standards. Further, EFRAG could monitor future sustainability reports to see if readability varies across EU member states, as a uniform European approach would be beneficial for the comparability of these reports."]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","Chapter 3 is clearer and better organised.  However, Chapter 3 frequently conflates 'topics' with 'impacts, risks and opportunities' ('IROs'). Para 22 is confusing when it says that information may be presented \"either at the topical level or at [IRO] level\". Such a dichotomy is confusing and incorrect. While topics refer to broad thematic areas, IROs are entity specific. The CSRD, as well as IFRS, TCFD, and TNFD consistently focus on the latter. Overemphasising 'topics' risks leading to generic, boilerplate disclosures that lack relevance and specificity. Chapter 3 would be clearer if it keeps the focus on IROs and plainly explain that depending on their nature and context such IROs may be defined at a general level - often corresponding to topics - and/or that information on their management may be similarly aggregated. This should be clarified also in provisions on entity-specific disclosures in paragraph 23 (and in paragraph 10 in Chapter 1) In Chapter 3.3.2, para 37 fails to mention that the purpose of financial material assessment is to not just to identify materiality information but also determine the material risks and opportunities, as required by the CSRD. In this regard, the risks and opportunities are only mentioned in the middle of para 38, making the text incoherent."]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","22.E3.","Comments on deleted datapoints in ESRS E3","I agree","ESRS are generally more concise and less demanding. Introducing further reductions (while keeping the coverage of all ESG factors as required by the CSRD) would create serious quality gaps between the ESRS disclosures and those based on the standards."]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We agree with these changes, noting that the suggested changes do not add a new burden.  This is particularly the case for the water-related metrics. In order to disclose the water consumption, the undertaking already has to calculate withdrawals and discharges, and such calculation and therefore the underlying data is subject to the assurance. Moving these implicit datapoints to the forefront as explicit data points makes the disclosure requirement clearer, compared to the previous ESRS where some of these datapoints were framed as \"may disclosures\". Whether or not these individual datapoints are to be disclosed is correctly subject to materiality of the information filter applied by the undertaking."]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree"]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome the changes made, including the clarification and minor additions to the datapoints in the metrics section. They provide for greater clarity and do not add further reporting burden."]
["Survey","Stowarzyszenie Pracownia na rzecz Wszystkich Istot","NGO","Poland","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","VEOLIA","Preparer (non-financial preparing a sustainability report)","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Yes  We welcome the improved presentation of the Standards, including: the reduction of the length of the text, the simplification of narrative paragraphs deemed overly technical or detailed; the positioning of AR directly after the disclosure requirements, focusing only on essential methodological elements and key presentation points, which significantly improves readability and understanding of the standards.  Nevertheless, the overall length of ESRS 1 could be further reduced, including by simplifying Chapter 3 on double materiality assessment (similar length as in Set 1 and simplified ESRS, 34 pages, 25 without annexes). Regarding the datapoints which are kept from the set 1, EFRAG should confirm that the wording changes brought to improve conciseness of the standards shouldn't lead to additional burden for the first application due to a \"fresh interpretation\" by the auditors or regulator."]
["Survey","VEOLIA","Preparer (non-financial preparing a sustainability report)","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Introduction of a more restrictive definition of recovery (E5 and Annex 2)  One of the main topics covered by ESRS E5 is waste recovery. The definition of \"recovery\" is given by the new  \"ANNEX II_Aggregated acronyms and glossary of terms _Set1Revision (clean)\" in its page 27, which excludes explicitly energy recovered from waste and focuses exclusively on material loops (reuse, repair and recycle). This definition is detrimental to the development of local sources of recovered energy, which:  contributes to Europe's energetic resilience and completes the benefits of the material loops, since the Energy Recovery facilities focus mainly on extracting all possible value from the non-recyclable fraction of municipal waste, in line with circular economy principles.  In addition, this definition lacks consistency with the waste hierarchy principles, which clearly ranks energy recovery at a higher priority level than waste elimination.    Regarding microplastics, the mandatory disclosure defined by ESRS E2 §16.b and AR1 is not at all feasible for Veolia. Let's take for example the activity of wastewater treatment, which is a significant one for the company in different parts of the world :  Neither the definition and the measurement methodology are officially established to date And if the above conditions were fulfilled, the measurement of rapidly varying flows of microplastics in the wastewater received for treatment and released after treatment would not be feasible in practice, both for technical and economical reasons, given the fact that no entity in the current framework is in charge of the continuous monitoring of this newly identified pollution, in a highly competitive wastewater treatment market."]
["Survey","SAIM GmbH","Consultant (including software vendor)","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We agree with moving the AR to below each relevant disclosure point and the removal of required tables and \"may disclosures\". However, some terms used are not fully defined, e.g. the definition of \"net zero\" has been removed."]
["Survey","SAIM GmbH","Consultant (including software vendor)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Deloitte","Auditor","Spain","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We agree with the focus on material information as an overarching principle and the emphasis on reporting IROs at the level at which they are managed. This is supported by EFRAG's greater emphasis on a top-down approach and guidance that topics clearly material/not material to the undertaking do not need to be assessed in depth.   However, the proposed simplified DMA process will continue to require considerable effort for undertakings, in particular for first-time application and in the assessment of impacts which involves consideration of their severity and significance from the perspective of affected stakeholders. Further non-binding guidance on how to identify affected stakeholders and assess impacts would be helpful.  We support the principle of including a definition of material information for stakeholders more broadly than investors. It should be clarified that the assessment is to be considered in the context of the information needs of the 'intended users' of the sustainability statement, rather than the information needs of any stakeholder. Better explanation is needed of the concept of 'general purpose sustainability statements' in ESRS 1:AR3.  The clarification of the connection between IROs and topics is helpful, but the overall organising architecture of the standards should be clearer. The standards consistently should allow an undertaking to disclose material information about material IROs aggregated at the level at which they are managed in the business. Once the undertaking has identified its material IROs, it should apply the topical standards to identify material information. However, the language in ESRS 1 and ESRS 2 is not sufficiently clear in this regard (e.g., ESRS2:2 references disclosing on IROs and disclosing on topics). Further non-mandatory guidance on how to apply 'reporting at the level IROs are managed' or 'groups of IROs' in practice would be helpful.  See also Q33."]
["Survey","Deloitte","Auditor","Spain","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I disagree","Extensive changes have been made to the overall structure, disclosure requirements and related guidance in a very short timeframe. While clarity and accessibility have been improved, there is insufficient time to consider the implications of the revisions across 12 standards. Furthermore, the revisions could lead to new unforeseen implementation issues, especially where new language has been introduced that is not clearly derived from existing standards and frameworks (such as the ISSB Standards).  We support the objective that ARs are streamlined, do not introduce additional disclosure requirements, and only include requirements needed to fulfil the objective of the disclosure requirements.  The work to determine what should remain in ARs as 'shall' and what should be moved to non-mandatory implementation guidance (NMIG) was done in a very short timeframe. We therefore recommend EFRAG validate that the following 'hierarchy' is consistently adopted across the standards: ARs should be included as 'shall' requirements that clearly support the related DR, and non-mandatory guidance in NMIG should be genuinely illustrative and not introduce additional disclosure requirements that are not directly included in the DR itself (see Q16).  To support a cost-effective system for preparers, enhance interoperability and support globally consistent and comparable disclosures, we recommend the ISSB's disclosure requirements are included as mandatory requirements in ESRS as far as possible."]
["Survey","Deloitte","Auditor","Spain","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","In our view, the proposed additional disclosure requirement on a statement of compliance in BP 1 is essential in the context of a fair presentation framework.   As stated in the EFRAG accompanying FAQs, the rationale for addition of the other new data points is to 'make explicit a separate element of required information' with the aim to 'clarify the reporting requirements' to meet 'the disclosure objective'. Whilst we do not disagree, this approach does not seem to have been applied consistently to all DRs.   The approach taken for these additional DPs seems to be that because the disclosures are needed to support the DR objectives, disclosure should be mandated. On the other hand, for other DRs a different approach seems to have been taken, simplifying the disclosure requirements without making a corresponding amendment to the objective itself, leading to an inconsistency between the objective and the related DRs. We think that clarity on this matter and consistency in the approach taken by EFRAG (additions vs deletions vs moving to NMIG) is key."]
["Survey","Deloitte","Auditor","Spain","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","In addition to our response to Q21, we do not agree with the revised approach proposed for measurement and disclosure of GHG emissions in ESRS E1. It introduces additional complexities and, as the BC acknowledges, the proposals would lead to differences with disclosure of GHG emissions under the ISSB Standards and the GHGP– e.g., with respect to the control approaches and the treatment of leases and joint ventures. As we stated in our earlier feedback to EFRAG, global consistency and comparability of GHG emissions measurement and disclosure is of particular importance to users. We note that GRI would now accept GHG emissions disclosure under the ISSB Standards as equivalent to the requirements under its new climate standard. There should therefore be no need for a difference between a 'risk and opportunity' or an 'impact' perspective on GHG emissions disclosure. We strongly recommend that EFRAG incorporates the ISSB requirements in full as far as possible (allowing for addition of EU-specific disclosures on, for example EU ETS and not permitting carbon offset in setting targets). We note that the GHGP is going to be revised significantly in the near future. This will likely resolve some of the issues that lead to the need for differences between ESRS and GHGP. We encourage EFRAG to contribute to this process in its capacity as an observing entity of the Independent Standards Board of the GHGP, and to leverage the potential for further alignment with the aim to remove deviations. We further note the recent announcement by the GHGP and ISO to harmonise their standards, which should serve further to align global practices in measurement of GHG emissions and allow EFRAG to reference global approaches without unnecessary deviations. Further consideration will be needed in the future on sources of guidance for measurement of financed emissions."]
["Survey","FEAD","Business association (other than association of financial institution)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","The CSRD is not strictly a \"compliance-based framework\" but a real support that allows highlighting the company's sustainability performance while also linking to financial reporting. We therefore support the introduction of the concept of \"fair representation,\" with the suggestion that clear guidelines be introduced for both preparers and auditors. Otherwise, there is a risk of producing reports with a very large number of entity-specific indicators."]
["Survey","DRSC","(National) standard setter","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","DRSC welcomes the changes made and that the ED ESRS focusses on shall-datapoints and explanatory ARs. However, at times, the AR seems to go beyond explanations, go beyond the content of the DR or are not considered to further contribute to the understanding. Therefore, further adjustments are needed.  Examples are:  -\tESRS 2.AR 36 provides examples for \"non-monetary resources\", however, par. 38 does not refer to non-monetary resources.  -\tESRS 2.AR 11, which merely refer to the glossary. -\tESRS 2.AR 28 repeats underlying principles from ESRS 1 or ESRS 1.AR 2 which refers to qualitative characteristics applying to all ESRS (not specifically needed in this context). -\t ED ESRS E4.AR 8 suggests that if the site of an undertaking is in a biodiversity sensitive area it \"is highly likely that its activities will negatively affect the area\". This assumption is pre-empting the result of the DMA of the reporting undertaking.  -\tED ESRS E1.AR 19: This AR extents the DR in par. 32 (specified in AR 18) for the specific case of financial control not conveying fair presentation of the GHG emissions.  -\tED ESRD E5.AR 2: This para requires an undertaking to designate certain materials in order to identify the material's characteristic, which constitutes an addition to the requirement in para 15(a) of ESRS E5."]
["Survey","DRSC","(National) standard setter","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","EFRAG changed the threshold for the requirement to disaggregate the metrics for characteristics of the undertaking's employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7). Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. This change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. Moreover, changes in the definitions/thresholds for the metrics regarding characteristics of the undertaking's employees, collective bargaining coverage and social dialogue in S1-5 and S1-7 lead to additional effort as it triggers changes in methodology and additional disclosure requirements. In particular, with respect to S1-5 and S1-7, this additional effort to collect the relevant data is considerable, because it may be necessary to report on more countries than before, as the calculation has been changed.  Moreover, the revised threshold for significant employment leads to inconsistencies over the years and may lead to strong discrepancies and additional reporting burden for undertakings depending on their distribution over countries."]
["Survey","DRSC","(National) standard setter","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","G1-6 is not able to address payment practices in the context of SME suppliers as laid out in the CSRD. For one, reporting undertakings usually do not categorise their suppliers by size (categorisation rather by risk, region etc.). Secondly, usually there are no \"standard payment terms\", i.e. for SME suppliers, that the reporting undertaking could disclose. Overall, this requirement does not seem suitable to address the SME specific context of payment practices."]
["Survey","Michelin","Preparer (non-financial preparing a sustainability report)","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Yes, the amendments proposed are more than welcome as they will greatly facilitate the preparation of the report and useability of the standards by preparers (the confusion between \"may\" and \"shall\" in the first version of the ESRS made their application extremely complex). Restricting the obligatory datapoints to the main body of the standard only is good legislative drafting practice. More generally, an effort has clearly been made in simplifying language that was often overburdensome and sometimes not at all easy to understand ."]
["Survey","Michelin","Preparer (non-financial preparing a sustainability report)","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","First, we consider amendments will improve the quality of the information disclosed, highlighting the compromise between the value and the cost to publish the information and then enhancing the effectiveness of sustainability reporting. The qualitative datapoints in particular were considered heavy and too detailed, at risk of drawing attention away from the essential information and \"losing\" the reader. The clear distinction between \"shall\" and \"may\" datapoints is also very welcome.  However, we cannot answer the question whether a balance has been achieved between burden reduction and the fulfilment of the objectives of the Green Deal. While preparers can share their views on the question of burden reduction, only the Commission services can evaluate to what extent the greater objectives of the Green Deal will also be met."]
["Survey","Michelin","Preparer (non-financial preparing a sustainability report)","France","22.S3","Comments on deleted datapoints in ESRS S3","I partially agree and partially disagree","First, we consider amendments will improve the quality of the information disclosed, highlighting the compromise between the value and the cost to publish the information and then enhancing the effectiveness of sustainability reporting. The qualitative datapoints in particular were considered heavy and too detailed, at risk of drawing attention away from the essential information and \"losing\" the reader. The clear distinction between \"shall\" and \"may\" datapoints is also very welcome.  However, we cannot answer the question whether a balance has been achieved between burden reduction and the fulfilment of the objectives of the Green Deal. While preparers can share their views on the question of burden reduction, only the Commission services can evaluate to what extent the greater objectives of the Green Deal will also be met."]
["Survey","Michelin","Preparer (non-financial preparing a sustainability report)","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","I.M.U. der Hans-Böckler-Stiftung","Academia","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","The elimination of duplicate requirements through the reassignment between general requirements (ESRS 2) and topic-specific standards significantly reduces the number of reporting points.  However, it is unacceptable that the draft ESRS weaken stakeholder engagement by removing essential reporting requirements on the involvement of employee representatives and other stakeholders. In particular, the deletion of reporting on strategic and business model changes in response to stakeholder views eliminates information that is crucial for transparency and accountability. Equally concerning is the removal of provisions detailing how companies engage with their own employees and employee representatives about significant actual and potential positive or negative impacts, and how the perspectives of the workforce are reflected in decision-making processes. Unlike the old standards, the draft no longer specifies: •\twhether engagement takes place directly with employees or through their representatives, •\tat which stage(s) the engagement occurs, the type and frequency of such engagement, and •\tthe role and highest-ranking position within the company responsible for ensuring that this dialogue happens and that its results are integrated into company practices. Leaving reporting on these critical processes optional undermines meaningful participation. Without clear and mandatory disclosure requirements, there is a high risk that employees and their representatives will not be adequately involved."]
["Survey","I.M.U. der Hans-Böckler-Stiftung","Academia","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I believe some of the deleted content should be maintained (please specify in the comments by indicating the relevant paragraph in the standard)"]
["Survey","I.M.U. der Hans-Böckler-Stiftung","Academia","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","We very much welcome the improvements in country-specific reporting on employment. Reporting will now apply to the ten countries with the largest number of employees, with a threshold of 50 or more employees - instead of the previous requirement for countries representing 10 % of the total workforce. For these \"Top 10\" countries, disclosures on employment numbers, collective bargaining coverage, and social dialogue are now mandatory. Shifting to a \"Top 10\" country approach is a clear step forward, as it ensures that reporting captures a larger and more representative portion of the workforce. Under the previous 10 % threshold, country-level disclosures often reflected only a small fraction of employees, leaving gaps in understanding the real impacts. Expanding coverage to the largest 10 countries provides more meaningful insights into how collective bargaining and social dialogue are applied across different regions."]
["Survey","Le Groupe La Poste","Preparer (non-financial preparing a sustainability report)","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","These simplifications will, in principle, have little impact on the DMA approach already implemented by La Poste for the FY 2024 Sustainability report and the assumptions that we already applied. The approach of using materiality as the cornerstone of reporting was already favoured in La Poste first Sustainability statement (points 2, 3, 4, 5, 6, 7 and 8 add nothing to what we are already doing). However it is of course understandable that some preparers need this to be made explicit.  We also find it unfortunate that the materiality analysis has been extended to ESRS2: this will require us to document the materiality analysis on topics where it seems doubtful that their materiality would be called into question for many companies (especially if we restrict them to wave 1 companies)."]
["Survey","Le Groupe La Poste","Preparer (non-financial preparing a sustainability report)","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Either it is mandatory/normative and must remain in the ESRS, or it is non-mandatory/ not normative and must – without any possible ambiguity – be provided for illustrative purposes in a separate document."]
["Survey","Le Groupe La Poste","Preparer (non-financial preparing a sustainability report)","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Le Groupe La Poste","Preparer (non-financial preparing a sustainability report)","France","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Le Groupe La Poste","Preparer (non-financial preparing a sustainability report)","France","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Responsible Business Alliance","Business association (other than association of financial institution)","United States","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The new methodology introduced under ESRS S1 to assess whether employees are paid an adequate wage establishes a benchmarking system based on comparison with the lowest wage. While in the EU this matter is addressed through the Adequate Minimum Wages Directive, challenges arise when looking outside the Union.  The language in the revised ESRS not only repeats but also amplifies the shortcomings of the previous methodology.   It creates disparities between EU and non-EU employees: the proposed disclosure still directs companies to prioritize the use of local legal minimum wages when calculating the gap between lowest wages and \"adequate\" wages for employees outside the EU, even though local legal minimum wages are typically much lower than both a local adequate wage (as defined under the EU directive) or other references such as living wage (as established in line with ILO principles on estimating living wage).  In our view, this methodology raises several legal and practical challenges. It risks creating a discriminatory approach toward employees outside the EU, obliges companies to collect complex data across multiple jurisdictions, and undermines the comparability of reported information, while not fostering the adoption of internationally agreed global standards that support policy coherence.  The RBA remains available to support and dialogue with EFRAG to identify forward looking options that address these concerns."]
["Survey","Federation of the European Sporting Goods Industry (FESI)","Business association (other than association of financial institution)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","The disclosure requirements on anticipated financial effects should be reconsidered. The concept of \"anticipated financial effects\" is not established or standardised, and ESRS 2 does not provide guidance on how such effects should be calculated. For example, it remains unclear whether the basis for calculation should be planning data or figures from the last financial year, and what level of granularity is required with regard to financial position, financial performance, and cash flows. Without clear methodology, these disclosures risk producing inconsistent and non-comparable information, undermining their usefulness.  If the requirement is retained, it should not be left to company discretion, as this weakens regulatory enforcement. Instead, the provision should either apply consistently to all companies or be removed altogether. At the same time, companies already retain flexibility to provide additional voluntary disclosures through materiality assessments. A pragmatic compromise, if any mandatory reporting on anticipated financial effects is maintained, would be to limit it initially to climate-related matters, where methodologies and expertise are comparatively more advanced."]
["Survey","Federation of the European Sporting Goods Industry (FESI)","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Federation of the European Sporting Goods Industry (FESI)","Business association (other than association of financial institution)","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"The amendments recognise that phase-in provisions exist and may be updated in the future, but they do not offer new or detailed instructions on how companies should apply phase-in data disclosure in practice. Until further guidance is provided, companies should continue to follow the original CSRD and ESRS texts for specifics on phase-in requirements. To stay consistent with the goal of simplifying and streamlining reporting, phase-in provisions should not become mandatory disclosure requirements.  The ESRS amendments  partly improve simplification, timing, and scope, but it is critical for the Commission and EFRAG to monitor implementation and consider possible future adjustments in line with future reglementary developments."]
["Survey","MedTech Europe","Business association (other than association of financial institution)","Belgium","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","MedTech Europe","Business association (other than association of financial institution)","Belgium","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","In general, there might be some reductions, but especially in the quantitative are new filters where added which might reduce the scope but at the same time creates new burdens for data generation."]
["Survey","MedTech Europe","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","MEDEF","Business association (other than association of financial institution)","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We welcome the proposed reliefs which should lead to a more cost-effective reporting without compromising quality: −\tclarification that the starting point for reporting is the scope of consolidated financial statements; −\treduced emphasis on direct data collection from value chain partners, with possibility to use estimates; −\tthe concept of \"undue cost or effort\" consistent with financial reporting practice;  −\tclarification that non-material activities may be excluded from the calculation of certain metrics.  We ask that the relief regarding skills and resources be included in the ESRS.  Even if some reliefs go beyond the ISSB provisions, being \"optional,\" we do not believe this will hinder interoperability. However, clarifications are necessary regarding how these reliefs fit into the fair presentation framework if it is adopted. Concerning joint operations, ESRS §92 seems increase the burden, implying that undertakings must include data from joint operations over which they have operational control, whereas preparers interpretation of the current standards (E1 apart) was that only own operations were concerned (except in the specific case of entity-specific indicators if this scope was deemed relevant by the company). In any case, ESRS S1 should also be targeted as it may be very delicate to obtain data on joint operations' workforce. We also wonder how this extension to operationally controlled joint operations fits in with the relief regarding data quality.  For the setting of climate objectives (E1-8) : the relief mentioned in ESRS1 §91 on \"undue costs and efforts\" should also be applicable for setting scope 3 objectives. They are most of the time very hard to quantify as they address actors across the whole value chain, without certainty for applying effectively the expected action plans. In any case, this relief should also apply to E1-8 on GHG emissions if estimates are subject to too much uncertainty."]
["Survey","MEDEF","Business association (other than association of financial institution)","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Companies operate globally and have investors outside of the EU who may be asking for ISSB compliance or operating in jurisdictions planning to make ISSB standards compulsory. Any reporting duplication or discrepancy of principle should therefore be avoided. Nevertheless, in our view, the international standards shouldn't necessary be the absolute global baseline and some datapoints may remain specific to this framework without being always embedded in the ESRS.  Indeed, to allow a real simplification of the ESRS without hampering the interoperability, any DP and DR which can be considered as less of a priority or too complex should be withdrawn from the standards and flagged in an appendix as necessary for the interoperability. It would enable any company needing to be interoperable an easy identification of what is needed without imposing an unnecessary burden on others."]
["Survey","MEDEF","Business association (other than association of financial institution)","France","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree","We are in favour of deleting paragraph 14, which poses a feasibility problem for companies with tens of thousands of direct suppliers. This disclosure requirement raises the question of how to identify SMEs around the world: what definition should be applied in non-EU jurisdictions ? It is therefore impossible to calculate and provides no useful information (payment terms can differ between economic sectors rather than based on the size of companies). Companies consider that paragraph 14 should be deleted. In addition, this requirement is not aligned with Directive 2011/7 of 16 February 2011 on combating late payments in commercial transactions which does not make any distinction based on the size of companies."]
["Survey","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","We recognise efforts to reduce reporting burdens while maintaining transparency, alignment with the Green Deal, and interoperability with ISSB standards. With targeted improvements, the amendments could better balance relief and transparency.  We welcome the \"undue cost or effort\" exemption, which eases burdens for complex data collection, and the flexibility for newly acquired subsidiaries, which reflects operational realities and clarifies consolidation timing. To ensure legal certainty and prevent divergent interpretations, it should be explicitly confirmed that applying these reliefs within the ESRS framework does not compromise the fair presentation of reported information. It is also essential that these reductions of reporting burdens are foreseen as permanent.  We support removing the systematic preference for direct value chain data. Section 5.2 should clarify that upstream and downstream information only applies when performing materiality assessments, not to metrics disclosure. As drafted, §60–67 and AR28 could require collection across all metrics, imposing excessive burdens. The principle on direct data (§62) should be nuanced to avoid creating a hierarchy over estimates.  For financial institutions, managed assets—particularly off-balance-sheet fiduciary assets—pose challenges because clients control investment decisions, risks, and sustainability choices. Reporting these assets could impose undue data collection costs. We suggest excluding these managed assets from the CSRD scope and making their impact reporting voluntary.  For insurers and financial institutions, reliable Scope 3 data are difficult to obtain. Extending the partial data coverage relief (§91) to E1-8 would support practical implementation while maintaining the Green Deal's objectives. We also recommend extending the relief for excluding joint operations without control from environmental metrics beyond E2–E5 to E1, given similar data constraints, while clarifying that the choice of an operational control approach remains optional."]
["Survey","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","We support the introduction of the 'undue cost or effort' relief and welcome its consistent application across all reporting areas, including the identification of material IROs and the calculation of metrics. Furthermore, we agree that flexibility without a fixed time limit provides companies with realistic pathways to improve data quality progressively, especially in complex or data-scarce contexts. We support the flexibility introduced by paragraph 91 but recommend clarifying that, in cases of limited data availability, value chain metrics may be entirely or partially estimated, rather than just \"partially estimated.\" This would better reflect preparers' realities and align with other existing international frameworks. The relief in paragraph 91 of ESRS currently excludes GHG emissions, despite these being highly uncertain, costly, and often based on unreliable or unavailable data. As drafted, full coverage would be required regardless of feasibility or data quality, potentially incentivizing low-quality estimates rather than high-quality, verified data for management purposes such as target setting. Regulation should emphasise accuracy and reliability, limiting mandatory estimates to cases that enhance understanding of the company's activities. We fully support the relief concept in paragraph 91 and strongly call for including GHG emissions. In case an operational control is chosen, paragraph 92 is presented as a relief but appears to establish disclosure requirements for joint operations with operational control under ESRS E2–E5, contradicting the defined consolidation scope."]
["Survey","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","We support emphasising fair presentation (FP) in ESRS to reinforce materiality and improve decision-usefulness of information.  However, the current wording risks reintroducing a compliance mindset, especially in the absence of auditing standards for sustainability reporting. Formalising \"completeness\", \"comparability\", \"accuracy\", and \"verifiability\" may lead preparers and auditors to adopt overly conservative interpretations.  FP must be applicable to forward-looking or uncertain disclosures; those based on estimates, evolving methodologies, or scenario analysis. \"Accuracy\" and \"verifiability\" should not imply absolute precision. \"Completeness\" risks being read as exhaustiveness, conflicting with simplification and encouraging over-reporting and over-auditing; we recommend removing \"complete\" from the definition. FP should be defined as an overarching principle prioritising relevance and proportionality. We suggest integrating into ESRS1 the concept articulated in the Basis for Conclusions (para 169). Compliance with ESRS should be presumed to achieve fair presentation, and the framework should emphasise the reasonable, informed judgment of the undertaking. It should be clarified that FP enables both additions and omissions: decision-useful context may be added when necessary, and requirements may be omitted as an outcome of the DMA or the information-materiality filter. An explicit formulation could be included: \"Where the strict application of an individual disclosure requirement would be disproportionate or not relevant to the undertaking's circumstances, the undertaking may adapt or omit such information, provided that the sustainability statement as a whole still achieves fair presentation of the undertaking's material impacts, risks, and opportunities.\"   Additionally, the Commission should issue Q&As clarifying the application/intent of FP for auditors – avoiding burdensome interpretations–and make explicit that the sustainability notion of FP differs from financial reporting and should not be treated as identical to the ISSB's. Finally, there should be alignment with the limited-assurance context under CSRD: disclosures need not be \"true\" in an absolute sense, particularly for forward-looking, qualitative, or complex quantitative matters."]
["Survey","CIMA","National supervisory authority & regulator","United Kingdom","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","Excessive Standards and Data Points  Currently, there are too many standards and an overwhelming number of data points that businesses are required to report. We therefore fully support the 57% reduction in standards and urge that these reporting requirements remain commensurate with the risks identified by companies' own assessments. Additionally, we are supportive of the following technical amendments -  a.\tThe removal of all voluntary standards. b.\tThe elimination of overlaps in climate reporting between ESRS 1 & 2. c.\tThe alignment of climate transition plan wording with IFRS S2. d.\tMaintaining high-level alignment with global objectives  e.\tInclusion of resilience considerations, as highlighted in the CIMA report, on uncertainty and adaptive capacity. f.\tThe removal of net zero terminology, which was unrealistic and confusing, in favour of broader and clearer concepts. g.\tConcentration on biodiversity through a single disclosure metric."]
["Survey","CIMA","National supervisory authority & regulator","United Kingdom","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","Implementation  a.\tCompanies already prepared for old ESRS will be fully prepared for simplified reporting, as metrics remain consistent. b.\tWe welcome the option of executive summaries and appendices but call for guidance on how presentation can avoid greenwashing. c.\tClarification is needed on appendices versus main text content and how these elements remain subject to assurance and digitalization rules."]
["Survey","LBP AM","Asset manager/Investor","France","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Overall, LBPAM supports the necessity of non-mandatory guidance"]
["Survey","LBP AM","Asset manager/Investor","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","As regards E2-4, LBPAM acknowledges that undertakings may have difficulties in the short term to measure the amount of secondary microplastics produced. However, this is a major source of pollution that needs to be properly addressed. Incentivizing companies to measure their production is a necessary first step for treating this serious issue."]
["Survey","LBP AM","Asset manager/Investor","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"LBPAM commends EFRAG's swift and comprehensive work to analyze initial reports and consult stakeholders. Revisions significantly streamline reporting requirements, introduce practical improvements while preserving core objectives of CSRD and ensuring EU remains a driving force on sustainability.  Continuous improvement LBPAM recommends adding a provision in ESRS 2 SBM-2 requiring to disclose whether and how governance bodies are informed of user feedback, fostering iterative quality enhancement (see_q11)  Historical Comparability  Companies should maintain a dedicated section on their website hosting all CSRD sustainability statements.  Climate risk We supports EFRAG's approach to climate risk transparency, notably: •\tInclusion of own operations and upstream/downstream value chain. •\tConsideration of short-, medium-, and long-term horizons. •\tClear distinction between physical and transition risks. •\tUse of climate scenarios and disclosure of mitigation/adaptation measures. However, comparability and robustness require: -\tRequire Standardized baseline scenarios, with the possibility to use alternative scenarios if proved that the alternative scenario is more accurate. This is notably to avoid references to undisclosed /black box internal scenarios.  For transition risks : IPCC SSP1 (\"Sustainability\"), for physical risks : IPCC SSP5 (\"Fossil-fueled development\") and SSP2 (\"Middle of the road\") for current trends •\tMandatory quantitative disclosure of anticipated financial effects (supporting Option 1 in EFRAG's consultation)   Climate transition plan :  LBPAM welcomes requirements for :  -\tGross GHG reduction targets (Scopes 1, 2, 3) without offsets.  -\tScience-based targets aligned with 1.5°C and EU objective by 2050.  -\tDisclosure on governance, financial planning, follow-up, locked-in emissions, and fossil-fuel Capex.  However, fossil-fuel Capex disclosure should be mandatory, not conditional on \"significance\" to avoid inconsistent interpretations.  NetZero Targets LBPAM regrets the removal of \"net zero\" from ESRS. Its inclusion in Set 1 improved disclosure quality and mitigated greenwashing risks. LBP AM recommends reinstating the glossary definition and E1-7 §60, clarifying residual emissions and removals"]
["Survey","Coca-Cola Europacific Partners","Preparer (non-financial preparing a sustainability report)","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","CCEP supports the objective of maintaining a high degree of interoperability between the ESRS and the IFRS Sustainability Disclosure Standards (ISSB S1 and S2). This is particularly important for large undertakings operating across multiple jurisdictions, such as CCEP, which are subject to both ESRS and ISSB requirements. We particularly recommend the inclusion of additional guidance on the application of the new overarching principle related to  \"reasonable and supportable information available without undue cost or effort\", as full alignment between ESRS and IFRS S1 and S2 is not achieved due to differences in scope where this concept is applied. Clear guidance is essential to prevent inconsistent interpretations and applications by preparers and auditors. In the absence of such guidance, there is a significant risk of subjective and divergent assessments, which could undermine the reliability, comparability, and decision-usefulness of sustainability information across entities and jurisdictions."]
["Survey","Coca-Cola Europacific Partners","Preparer (non-financial preparing a sustainability report)","United Kingdom","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I agree","We agree that that change of threshold will result in more useful information and will not result in an increased reporting burden as this information should be readily available."]
["Survey","MSCI ESG Research","User (analyst, data provider, rating agency, etc.)","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We support the overall direction of the amendments, which provide greater clarity and flexibility in the application of the Double Materiality Assessment (DMA) while aiming to reduce unnecessary complexity. However, sector specific guidance is needed for preparers to determine which information is relevant. This is particularly important with respect to the value chain boundaries in the financial sector."]
["Survey","MSCI ESG Research","User (analyst, data provider, rating agency, etc.)","United Kingdom","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I partially agree and partially disagree"]
["Survey","MSCI ESG Research","User (analyst, data provider, rating agency, etc.)","United Kingdom","29.","SFDR and other EU datapoints in Appendix B of Amended ESRS 2 The Omnibus proposals have not changed the general objective of supporting the creation of the data infrastructure necessary for implementing the Sustainable Finance Disclosure Regulation (SFDR). Input from investors confirms the need to implement the correct flow of information from their investee. However evidence also suggests some of the Principal Adverse Indicators (PAI) are not considered relevant in practice. As part of the systematic review of the datapoints for their reduction, EFRAG has assessed the relevance of the SFDR PAIs, as well as the level of coverage of them resulting from the general datapoint reduction. Appendix 4 of the Basis for Conclusions (BfC) illustrates how the EU datapoints in Appendix B of ESRS 2 (now Appendix A of Amended ESRS 2) have been modified. The key changes for Environmental standards (ESRS E1-E5) are :  (a)     8 SFDR PAI sensitive DPs have been deleted but they were either overlapping with other DPs or can be derived from other information (E1-5, para.38, 40-43; E1-6 para44, 53-55; E3-1, para 14; E3-4, para 29; E5-5 para 37 (d) and 39); (b) 1 SFDR PAI sensitive DPs in Appendix B (indicator number 12 Table #2 of Annex) was removed, following EFRAG’s approach of reducing the content provisions related to PAT under topical standards. This refers to the topic of marine resources, which is not in scope of ESRS E3. The key changes for Social standards (ESRS S1-S4) are:  (a)  this was a consolidation exercise. Firstly, for the policies related to human rights and for the alignment with UNGP and OECD MNE Guidelines (two SFDR PAI number 9 Table #3 and Indicator number 11 Table #1 of Annex 1), eight datapoints from the four Social standards have been merged into a “human rights policy” in ESRS 2 GDPR-P, for the four affected stakeholder groups. Secondly, the indicator in relation to severe human rights cases (SFDR PAI number 14 of  Table #3 and number 10 of Table #1 of Annex 1) have been merged into one and it is maintained across the four Social standards. (b)  a small number of amendments on the scope has taken place for SFDR PAI Indicator 3 of Table #3 in relation to days lost. Fatalities (ESRS S1-13) has been deleted from its scope. The scope of revised human rights incidents datapoint (ESRS S1-16, S2-3, S3-3, S4-3) is now clarified. There were no changes in the ESRS G1. In conclusion, despite the general significant reduction in DPs, the coverage of SFDR PAI has been only marginally reduced and thanks to a limited number of amendments, the relevance of the corresponding information is increased. Do you agree with the way the SFDR PAI have been incorporated in the Amended ESRS? You are invited to explain the reason why you agree or disagree and to provide your suggestions for improvements or alternative simplification proposals, if any.","I partially agree and partially disagree"]
["Survey","Sustainability Makers","Business association (other than association of financial institution)","Italy","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","We express a clear preference for Option 2, which prioritizes qualitative disclosure while providing companies with the voluntary possibility to quantify such effects if they consider it relevant and appropriate,    We believe that this approach offers several significant advantages. First, it ensures a high degree of flexibility, which is particularly important given the current diversity in company maturity, and reporting capacity for whom mandatory quantitative disclosure of financial impacts could represent an excessive and disproportionate burden.    Second, Option 2 enhances the practical applicability and inclusiveness of the ESRS framework across a broad range of organizations. Moreover, we recognize that achieving full comparability in quantitative financial impact disclosures is extremely challenging. Variations in methodologies, assumptions, and data availability make it unlikely that such figures will be directly comparable across entities in the short to medium term. As a result, imposing strict quantitative requirements risks generating information that is inconsistent, potentially misleading, or overly sensitive, especially where disclosure may touch upon confidential or commercially sensitive data.   Option two effectively addresses preparers' concerns by allowing organizations to manage disclosure in a way that respects confidentiality and the limitations of current measurement capabilities, while still encouraging transparency through qualitative explanations. This reduces the risk of arbitrary or incomplete reporting, promoting more reliable and meaningful communication.   For these reasons, we strongly recommend adopting Option 2 as the preferred approach for disclosing anticipated financial effects in the ESRS."]
["Survey","Sustainability Makers","Business association (other than association of financial institution)","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I partially agree and partially disagree","We acknowledge that modifying the country-by-country disclosure threshold may reduce preparers' burden and improve practical applicability. However, depending on the specific level of the threshold, there could be a risk of omitting relevant information necessary for stakeholders to fully understand the company's geographic exposure, tax contributions, and operational impact. While the amendment partially balances reporting effort and transparency, further clarification is needed to ensure consistency, comparability, and meaningful disclosures across organizations."]
["Survey","Sustainability Makers","Business association (other than association of financial institution)","Italy","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","While the effort to make the standards more flexible and applicable to SMEs is recognized, concerns remain regarding clarity, practicality, and proportionality, which could still impose a significant burden on smaller companies."]
["Survey","Sustainability Makers","Business association (other than association of financial institution)","Italy","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","While we appreciate the proposed amendments and the increased flexibility, such as the encouraged use of appendices, these modifications merely clarify existing possibilities rather than deliver meaningful simplification. The changes, though positive for improving document structure and readability, do not contribute to substantially reducing implementation burdens or overall reporting complexity."]
["Survey","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1; G1","NMIG can serve as an orientation tool—especially for preparers in the early stages of implementation—by illustrating how disclosures might be structured or interpreted. However, the effectiveness of the NIMG depends on universal recognition of its non-binding status.   Its non-binding status should be explicitly stated and uniformly understood by preparers and auditors, with no implied obligation to follow the provided examples. To reinforce this position, NMIG should be explicitly excluded from audit procedures, kept separate from legislative text and be strictly aligned with the ESRS standards through robust due process. This approach will ensure NMIG serves as a helpful reference tool while preventing unintended reporting burdens and complexity.  However, we do still see the need for sustainability assurance standards for auditors to harmonize audit practices and to minimize the audit burden. Audit firms across member states and within countries are currently inconsistent in the level of detail they require for (limited) assurance engagements (e.g. evidence request) and in the way they interpret regulatory requirements. To avoid divergences between audit firms and between member states, the EU Commission should provide  timely assurance standards for sustainability reporting as it was originally foreseen in the CSRD (i.e. by 2026).   On G1: The table on standard payment terms (G1-6) should be deleted.  Disclosing information of the standard payment terms by \"main category of suppliers, including SME's\" is not feasible and does not provide any value. The standard payment terms generally do not make any differentiation between supplier types. Additionally, for multinational companies with thousands of suppliers globally, a categorization of suppliers into SMEs and Non-SMEs is not possible."]
["Survey","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","We strongly disagree with the proposal to change the threshold for the disclosure as the European Commission's intention to reduce reporting burdens is not achieved by this change. While the intent to gather more granular data is understandable, this change will, in many cases, significantly increase both the reporting requirements and the audit scope.  Changing the reporting requirement from \"50 employees and 10% of total headcount\" to the \"top 10 largest countries by employee headcount (if >50 employees)\" will force many multinational companies to report on more countries than before. Each new country added to the reporting list creates its own unique challenges for data collection, especially since there are often large differences between the established data infrastructure and IT systems (especially in relation to the disclosures for S1-7 Social Dialogue (former S1-8))."]
["Survey","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The ESRS 1 cross-cutting standard continues to be especially important, as it lays the foundation for the sustainability statement. While certain changes introduce more clarity or strengthen pragmatic and focused sustainability reporting, others increase the complexity and risk limiting the comparability of sustainability information. We especially oppose the proposed \"undue cost or effort\" principle and \"partial scope\" reporting as they will significantly weaken data quality, availability and comparability, undermining sustainability reporting's role in the sustainability transformation and an even level playing field. We therefore propose to eliminate these reliefs. We think that there are other measures to facilitate implementation and reporting without weakening sustainability reporting in such an extreme sense."]
["Survey","ASRO - National Standards Body in Romania","Standard setting initiative","Romania","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","While welcoming the simplification, we consider that ESRS should explicitly recognize European and international standards as means to to demonstrate compliance and ensure coherence with other EU frameworks. Using standards will help make the DMA workable, comparable and avoid duplication in many areas."]
["Survey","ASRO - National Standards Body in Romania","Standard setting initiative","Romania","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","We recommend that, to avoid duplication, a single standards-based management measurement  (methods and controls) may be used across EU requirements and cross-referenced once without recalculation."]
["Survey","ASRO - National Standards Body in Romania","Standard setting initiative","Romania","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","We support ESRS2, BP-1, E5-4 and E5-5. For E 2-4 implementation should use standards developed by ESOs. Where no standards exist, the EC should issue a formal standardization request and SME guidance should signpost the EN, to one standard-based measurement which can be re-used across EU requirements without parallel methods."]
["Survey","ASRO - National Standards Body in Romania","Standard setting initiative","Romania","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The new datapoint on secondary microplastics is decision-useful, but methodologies remain immature. The Commission should issue a formal standardisation request to CEN/CENELEC to develop an EN method, referenced in SME guidance to keep burden proportionate."]
["Survey","ASRO - National Standards Body in Romania","Standard setting initiative","Romania","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Simplification is welcome. To preserve comparability, include a minimal quantitative core for due-diligence outcomes: (i) share of value-chain workers covered by risk screening; (ii) share with corrective actions agreed and closed on time; and (iii) incidence rate of serious non-compliance. Permit cross-reference to processes implemented under standards developed by CEN/CENELEC (and, where relevant, ISO/IEC), with SME-proportionate procedures."]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","ANC acknowledges that EFRAG has introduced meaningful simplifications to the double materiality assessment process. In particular, ANC welcomes: •\tthe possibility of adopting a top-down approach rather than a bottom-up one; •\tthe shift in focus from the IRO-level to the topic-level; and •\tthe simplification of AR 16 (Appendix A). However, ANC considers that further structural and editorial changes should be undertaken to ensure consistency with the top-down approach (detailed comments provided in Part 3 – Excel file): 1.\tStreamline references to materiality assessment in ESRS 2, in particular IRO-1 (§26), which currently requires eight data points to describe the DMA process, as this conflicts with the simplified approach proposed in ESRS 1; 2.\tRelocate methodological or illustrative elements specific to the bottom-up approach to the Application Requirements, including factors on severity, precedence of severity over likelihood, criteria for positive impacts, methodological elements on dependencies (§31-32, §41-44); 3.\tAddress remaining ambiguity between top-down and bottom-up approaches, including the formulations overly focused on individual IROs and clarify terms such as \"relevant information\" (§22) and \"appropriate level of aggregation\" (ESRS 2 AR 23); 4.\tClarify that thresholds serve to determine and prioritise material topics, without implying the need for separate scoring of each criterion or severity characteristic (§28, AR 5c, AR 7); and 5.\tSimplify update requirement by specifying that the DMA process and its conclusions shall be updated only in case of significant events or material changes in circumstances (§29).  [See proposed wording in Part 3 – Excel file regarding IRO-1 (ESRS 2 §26), thresholds (ESRS 1 AR5c), update of the DMA (ESRS 1 §29), and ambiguous wordings (ESRS 1 §22, ESRS 2 AR23).]"]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","We have different views in our jurisdiction. In that context, ANC supports a hybrid approach. Option 1 could apply only to anticipated financial effects of material climate risks, reflecting financial materiality and ensuring ISSB interoperability, given the maturity of climate reporting. Option 2 could apply to other environmental topics. Requirements in ESRS 2 and E1 should explicitly refer to ISSB reliefs. Commercial sensitivity should be addressed through a relief at Level 1.  ANC recalls that AFE already benefit from phasing-in provisions. It should be clarified that they apply from the date of adoption of the Delegated Act at EU level, not from the transposition date at Member State level, to ensure level playing field. Support for Option 1: •\tPublic authority, auditors, civil society highlight that quantitative information refine risk assessment, complements resilience analysis, provide forward-looking information, supporting financial materiality and ISSB interoperability. •\tOption 1 offers flexibility regarding estimates, scope, granularity. •\tClimate-related reporting has matured since the TCFD (2017). •\tAsset managers support Option 1, as they rely solely on public disclosures. Support for Option 2: •\tCompanies point out risks of disclosing projections covering medium- and long-term horizons based on assumptions that change rapidly. •\tIt would significantly increase companies' liability. •\tIt is impossible to provide such quantitative information without disclosing sensitive financial information; in the field of financial reporting, companies are not required to disclose financial planning.  Proposed wording: •\tESRS 2 §23 (b): \"the anticipated effects of its material climate risks on its financial position, financial performance and cash flows, including the time horizons for which those effects could reasonably be expected to occur;\" •\t\"The undertaking may comply with ESRS 2 SBM-3, by reporting only qualitative disclosures for the first three years, starting from the application date specified in a Commission Delegated Act\""]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","22.E1.","Comments on deleted datapoints in ESRS E1","I agree","[See detailed comments in Part 3 – Excel file]"]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","ANC supports mandatory datapoints on water withdrawal and discharges in ESRS E3, as they provide a more accurate reflection of the water cycle and reinforce impact materiality. ANC recommends retaining datapoints on the management of relationships with suppliers in ESRS G1 (previously in G1-2, now deleted) as a higher priority than training of procurement teams. ANC strongly rejects changing datapoints on confirmed incidents from \"may\" to \"shall\" in ESRS G1, as they are highly sensitive and of limited relevance. Such disclosure could conflict with the right against self-incrimination under the European Convention on Human Rights and expose companies to investigations by third-country authorities (e.g., US Department of Justice), giving non-EU competitors an advantage. Furthermore, confirmed incidents are not a reliable proxy for assessing anti-corruption policy effectiveness. ANC considers that safeguards around the disclosure of a biodiversity transition plan in ESRS E4 do not create an undue burden and improve reliability through audit. However, clarifications are required: •\tThe plan should be made public by the company itself, not by a third party and the term \"publicly available\" should be clearly define. •\tA distinction should be made between a biodiversity action plan and a biodiversity transition plan. ANC supports adding a definition of \"transition plan\" in the ESRS glossary and enhancing consistency between ESRS E1-1 and E4-1. A transition plan should be understood, as in E1, as a transformative tool for the business model, requiring only key elements: integration into strategy, alignment of targets, actions, and resources, and governance approval. Finally, compatibility with the Kunming-Montreal Global Biodiversity Framework raises practical challenges. Companies should be allowed to present a plan even if not yet fully compatible, provided they disclose current compatibility and steps toward improvement. The contradiction between \"alignment\" (main body) and \"compatibility\" (application requirements) should be resolved by retaining \"compatibility\"."]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","As regards biodiversity-related target setting, we support providing more guidance to reflect the latest methodological trends and ensure stronger alignment with science-based frameworks in the NMIG.  Proposed wording on target setting (NMIG): •\t[New]: \"Biodiversity-related targets should: o\trely on material impacts and dependencies, prioritising significant activities, high-risk watersheds, and high-impact commodities; o\tcontribute to alignment with ecological thresholds, policy objectives, and recognised frameworks, including SBTN and the Kunming-Montreal Global Biodiversity Framework; and o\tfocus on key impacts, such as land use change and ecosystem conversion (e.g., expanding from zero-deforestation to zero-conversion policies for all natural ecosystems), while considering the local ecological context. •\tWhen appropriate, the undertaking may refer to the following sources: o\tTNFD, which provides examples of quantifiable targets related to direct biodiversity pressures and nature state; o\tSBTN, which provides guidance for establishing targets and/or collecting associated data on pressures, impacts, and dependencies, as well as more detailed guidance for targets related to terrestrial ecosystem use (e.g., non-conversion of natural ecosystems, reducing land footprint, and landscape-level commitments).\"  Key considerations for implementation and open questions from French stakeholders to be addressed in the longer term by EFRAG: •\tHow to reconcile local site-level targets with global science-based ambitions? •\tHow to balance ambitious global targets, which may currently be unattainable, with practical and credible action plans? •\tHow to define the appropriate scope/geography: site, watershed, country, or consolidated? •\tHow to apply ecological thresholds locally in alignment with global commitments? •\tHow should target-setting differ between physical economy actors and financial actors?  Finally, we encourage a progressive implementation approach. Expanding coverage of activities and subsidiaries in phases allows for learning, internal acceptance, and capacity building.  [See key additional considerations in Part 3 – Excel file regarding value chain (§9), direct biodiversity pressures (AR6), and standardised metrics (§21).]"]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","[See detailed comments in Part 3 – Excel file]"]
["Survey","Autorité des normes comptables (ANC)","(National) standard setter","France","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","[See detailed comments in Part 3 – Excel file]"]
["Survey","Corporatings","User (analyst, data provider, rating agency, etc.)","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","I agree with the sentiment that impacts should be reported on when the company has to maintain significant actions to mitigate them.  However, I think this phrasing may be a source of confusion and therefore additional preparer-assurance discussions and costs.  In what cases is there an impact that would be material before mitigation actions, immaterial after mitigation action, but the mitigation action wouldn't be significant?  Unless EFRAG provides clear examples of that, and guidelines to that notion of \"significant\", this will just be another additional point of debate and cost between preparers, assurance providers, and users."]
["Survey","Corporatings","User (analyst, data provider, rating agency, etc.)","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Corporatings","User (analyst, data provider, rating agency, etc.)","France","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","I agree with the concern that the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, and therefore does not inform users on the payment of adequate wages."]
["Survey","Corporatings","User (analyst, data provider, rating agency, etc.)","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","Corporatings","User (analyst, data provider, rating agency, etc.)","France","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","ACEA","Business association (other than association of financial institution)","Belgium","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Mainly the enhanced readability and usability of the standards under Level 3, reduction of complexity and duplication through simplification of GDRs and reducing mandatory PATs, and shifting towards more principle-based approach and the ability to report PATs at higher aggregation level.   These changes reduce complexity and duplication, making it easier for preparers to navigate the requirements and focus on material information."]
["Survey","ACEA","Business association (other than association of financial institution)","Belgium","22.E2.","Comments on deleted datapoints in ESRS E2","I disagree","Changes are purely editoral or aimed at improving readability and comrehension, instead of an actual reduction in the number of disclosures. The overall scope and complexity of the disclosures remain largely unchanged. The deletion of datapoints primarily affects how requirements are presented, not what is required. Deletion of datapoints does not necessarily translate into a proportional reduction in the substantive reporting scope or effort.   We do not expect a significantly reduced reporting volume under the amended ESRS. Instead, the changes may help reduce effort in documentation and coordination with auditors. For example, the introduced options for burden reliefs may simplify internal discussions and reduce the need to justify the omission of non-material items. It is important that this distinction is clearly communicated: while the number of datapoints has decreased, the underlying disclosure obligations remain intact. This will help manage expectations and avoid misinterpretations regarding the actual simplification impact of the amendments.  Additionally, we have concerns with the addition of new mandatory disclosures, going against the purpose of the revision of the ESRS.  Simplification should be focused on reduction of efforts in data collection, documentation, and coordination with auditors."]
["Survey","ACEA","Business association (other than association of financial institution)","Belgium","22.E5.","Comments on deleted datapoints in ESRS E5","I disagree","Changes are purely editoral or aimed at improving readability and comrehension, instead of an actual reduction in the number of disclosures. The overall scope and complexity of the disclosures remain largely unchanged. The deletion of datapoints primarily affects how requirements are presented, not what is required. Deletion of datapoints does not necessarily translate into a proportional reduction in the substantive reporting scope or effort.   We do not expect a significantly reduced reporting volume under the amended ESRS. Instead, the changes may help reduce effort in documentation and coordination with auditors. For example, the introduced options for burden reliefs may simplify internal discussions and reduce the need to justify the omission of non-material items. It is important that this distinction is clearly communicated: while the number of datapoints has decreased, the underlying disclosure obligations remain intact. This will help manage expectations and avoid misinterpretations regarding the actual simplification impact of the amendments.  Additionally, we have concerns with the addition of new mandatory disclosures, going against the purpose of the revision of the ESRS.  Simplification should be focused on reduction of efforts in data collection, documentation, and coordination with auditors."]
["Survey","ACEA","Business association (other than association of financial institution)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Further simplification on AR 26 is needed. Specification of the, until  now, optional examples of how targets can be set is not needed because companies are best placed to assess which targets are most appropriate for them. Flexible target setting options are essential. Additionally, detailed guidance undermines the DMA by creating a \"checklist\" effect. This pressures companies to report on a topic even if their own assessment deems it non-material.   It is strongly recommended that AR 26 is reviewed and  replaced with simpler, principles-based guidance. This would empower companies to set targets that are relevant to their specific material impacts, if any exist, rather than forcing compliance with a one-size-fits-all standard."]
["Survey","ACEA","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree","When it comes to alignment with the EU Payment Transparency Directive (EU PTD), we are still missing total alignment with the EU PTD, with regards to salary/wage components. This might lead to different calculation approaches, especially when the EU PTD is translated differently in the member states. Therefore we recommend to keep the datapoint regarding gender pay gap, but make it voluntary in nature."]
["Survey","ACEA","Business association (other than association of financial institution)","Belgium","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See Part 3"]
["Survey","Arbeitskreis Externe Unternehmensberichterstattung (AKEU) of the Schmalen-bach-Gesellschaft für Betriebswirtschaft e. V.","Other - please specify (required)","Germany","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","The AKEU member organizations partially agree that the proposed amendments on burden reliefs strike a better balance between easing preparers' reporting challenges and preserving transparency in line with the EU Green Deal and global interoperability. Respondents generally welcome the horizontal burden reliefs as a meaningful step providing a legal basis for practices such as using estimates or partial-scope calculations, reducing the need for creating entirely new datapoints, and facilitating discussions with auditors. These clarifications can help companies focus on strategically relevant topics and reduce complexity in specific cases, such as acquisitions close to year-end or the exclusion of non-significant activities.  AKEU members assess the expected overall impact on reporting costs as moderate rather than substantial. According to our member survey, 54% anticipate a moderate reduction, 31% no change, and 8% even a moderate increase. The ability to use estimates, partial-scope calculations, and reliefs for acquisitions are seen as the most practical provisions, but many companies already apply such approaches in practice, making incremental savings limited. Opinions on the \"undue cost or effort\" clause are mixed: while some value it as pragmatic, others view it as too vague to deliver consistent relief.  The reliefs also affect preparers differently depending on their stage of implementation. Wave-1-companies have already built systems and auditor-aligned processes, so they consider the new reliefs as coming too late to reduce current effort; benefits may materialize later, particularly for value-chain-datapoints. By contrast, Wave-2 and less mature preparers are likely to benefit more from the flexibility, as the reliefs allow them to avoid strategically irrelevant disclosures and better align reporting with corporate strategy.  Overall, AKEU members consider the reliefs a positive step but not as fundamentally reducing the reporting burden. They are most effective when targeted at new preparers (e.g., Wave-2-firms), while many Wave-1-preparers expect only incremental gains."]
["Survey","Arbeitskreis Externe Unternehmensberichterstattung (AKEU) of the Schmalen-bach-Gesellschaft für Betriebswirtschaft e. V.","Other - please specify (required)","Germany","22.E1.","Comments on deleted datapoints in ESRS E1","I partially agree and partially disagree","The AKEU member organizations partially agree that the proposed reduction in mandatory datapoints represents a step toward balancing burden reduction with the objectives of the EU Green Deal. The revisions improve readability and structure, and in some areas the amendments reduce unnecessary scope. However, the impact on reporting costs is expected to remain modest at best.  Respondents consistently emphasize that the datapoints removed are often qualitative and low-cost to maintain, while the most resource-intensive datapoints remain. Chief among these are quantitative metrics requiring internal operational or value chain data, such as Scope 3 emissions, which demand extensive coordination, validation, and methodological development. Similarly, anticipated financial effects impose high recurring costs due to uncertainty, lack of guidance, and sensitive forward-looking estimates. Social datapoints such as S1-9 (adequate wages, requiring checks against ~500 ILO benchmarks), S1-15 (remuneration medians), and health- or discrimination-related indicators are seen as disproportionate burdens, particularly given data protection issues and high manual effort.  With respect to amendments, AKEU preparer members point to increased costs from S1-5 (broader employee country breakdown), E2-4 (\"any material pollutant\"), and E1 transition plan requirements (fossil CapEx, locked-in emissions, interim targets, financial planning). While some changes create simplifications, others add granularity or new concepts (e.g., gross vs. net reporting, fair presentation), resulting in a mixed net effect.  Quantitatively, 69% of respondents expect very limited cost reductions and 23% none at all. 45% see some cost relief from amendments, while 27% report no change, and 27% expect some increases. 50% plan to stop reporting deleted datapoints, though 25% will continue selected disclosures for investor expectations, ratings, or internal KPIs; the remaining 25% are undecided.  In sum, AKEU members think that the revisions modestly streamline ESRS but do not eliminate the costliest datapoints. The resulting practical cost relief is therefore limited."]
["Survey","Arbeitskreis Externe Unternehmensberichterstattung (AKEU) of the Schmalen-bach-Gesellschaft für Betriebswirtschaft e. V.","Other - please specify (required)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","The AKEU member organizations partially agree that the proposed reduction in mandatory datapoints represents a step toward balancing burden reduction with the objectives of the EU Green Deal. The revisions improve readability and structure, and in some areas the amendments reduce unnecessary scope. However, the impact on reporting costs is expected to remain modest at best.  Respondents consistently emphasize that the datapoints removed are often qualitative and low-cost to maintain, while the most resource-intensive datapoints remain. Chief among these are quantitative metrics requiring internal operational or value chain data, such as Scope 3 emissions, which demand extensive coordination, validation, and methodological development. Similarly, anticipated financial effects impose high recurring costs due to uncertainty, lack of guidance, and sensitive forward-looking estimates. Social datapoints such as S1-9 (adequate wages, requiring checks against ~500 ILO benchmarks), S1-15 (remuneration medians), and health- or discrimination-related indicators are seen as disproportionate burdens, particularly given data protection issues and high manual effort.  With respect to amendments, AKEU preparer members point to increased costs from S1-5 (broader employee country breakdown), E2-4 (\"any material pollutant\"), and E1 transition plan requirements (fossil CapEx, locked-in emissions, interim targets, financial planning). While some changes create simplifications, others add granularity or new concepts (e.g., gross vs. net reporting, fair presentation), resulting in a mixed net effect.  Quantitatively, 69% of respondents expect very limited cost reductions and 23% none at all. 45% see some cost relief from amendments, while 27% report no change, and 27% expect some increases. 50% plan to stop reporting deleted datapoints, though 25% will continue selected disclosures for investor expectations, ratings, or internal KPIs; the remaining 25% are undecided.  In sum, AKEU members think that the revisions modestly streamline ESRS but do not eliminate the costliest datapoints. The resulting practical cost relief is therefore limited."]
["Survey","Decathlon","Preparer (non-financial preparing a sustainability report)","France","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Decathlon welcomes the evolutions introduced and the simplifications proposed. Nevertheless, it is essential to have a globally interoperable standard across the world to avoid reporting burden. In order for the regulatory evolutions related to non-financial reporting to be an argument to engage undertakings in their transitions, it is important that the obligations and methodologies are globally interoperable. Furthermore, it is necessary to simplify concepts, such as double materiality, both in its approach and to foster comparability among undertakings. It is also necessary to rely on the core principles of the CSRD by adopting a pragmatic and progressive approach. Clear implementation guides are necessary to ensure uniformity in the responses and in the published CSRDs."]
["Survey","Decathlon","Preparer (non-financial preparing a sustainability report)","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","The anticipated financial effects are complex to implement given the existing methodologies, a more significant phase-in must be implemented to permit a comparable implementation among undertakings.",null,null,""]
["Survey","Decathlon","Preparer (non-financial preparing a sustainability report)","France","35.S1-13."," Do you agree with the amendments of this chapter? ","I agree","Fatalities due to ill health among non employees or on-sites workers excluded => (I agree) Deletion of days lost to fatalities → (I agree)","S1","Disclosure Requirement S1-13 - Health and Safety metrics",""]
["Survey","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Support: -\tWe acknowledge the effort to clarify how remediation, mitigation, and prevention actions should be considered in the DMA. -\tThe guidance is seen as a step forward in providing structure to a previously ambiguous area, for aligning disclosure with the fair presentation principle, and clarifying how remediation actions factor into actual impact reporting.  Areas of improvement: -\tThe current guidance does not sufficiently resolve the ambiguity between applying a gross versus a net perspective. It remains unclear when impacts should be assessed before actions (gross) and when after actions (net). This lack of clarity may lead to inconsistent interpretations, which undermines both the comparability and the relevance of the disclosures. -\tProvide more clarity on whether IROs should be assessed 'gross or net', as the current ESRS does not give guidance. How it is currently described in the revised ESRSs is still difficult to interpret and Appendix C is also difficult to grasp. It could benefit from an alternative, simpler presentation (e.g. flowchart). -\tProvide clear examples on how to assess mitigating and preventive actions, and when a risk or impact has been fully mitigated (below materiality threshold). -\tIncluding additional guidance is necessary to ensure a common approach across companies. -\tLanguage should be reviewed to ensure that 'risks' are not referred to in the case of impacts. -\tFor both actual and potential impacts, clarification is required for the cases when impact occurred during the year or became material in the reporting year. -\tWe agree that the new guidance provides clarification on how to factor remediation, mitigation and prevention actions into the DMA.  However, the interaction between severity and likelihood could still be challenging in practice. -\tThere is a lack of clarity as to how to consider human rights impacts."]
["Survey","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Most prepares opted for Option 2, as it balances transparency and feasibility while protecting sensitive information and recognizing current data limitations. Many of the FEA respondents abstained from the answer as they are of the opinion the best way forward is yet to be found. Option 1 was named by two preparers as they favoured alignment with IFRS and clearer phased approaches to eventual quantitative disclosure. Some preparers oppose any form of mandated anticipated financial effects disclosure due to inherent uncertainties and legal risks.  Although FEA members support interoperability with IFRS SDS, critics state that quantitative disclosure is premature due to: -\tLack of mature methodologies -\tHigh uncertainty and difficulty isolating sustainability-related financial effects. -\tCommercial sensitivity and competitive risks -\tWide variation across industries undermines comparability. -\tConcern that detailed quantitative disclosures could lead to excessive scrutiny and legal risks.  Option 2: Qualitative Disclosure (with voluntary quantitative info) -\tFavoured by many as more practical, flexible, and proportionate for current implementation stages. -\tQualitative info allows users to understand nature and direction of impacts without unreliable or sensitive numeric data. -\tVoluntary quantitative disclosure allowed when reliable and meaningful. -\tRecognizes uncertainty and immaturity of financial effect assessment methods. -\tAvoids forced disclosure of sensitive or speculative figures, protecting competitive position. -\tSome argue no fixed time limits are needed, as market forces and peer benchmarking will naturally increase transparency over time."]
["Survey","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","Support: -\tThe removal of the voluntary data point requirement is reasonable, as it ensures that efforts to address the gender pay gap remain aligned with the EU Pay Transparency Directive, which already mandates detailed breakdowns.  Areas of improvement: -\tIncluding the adjusted pay gap, even on a voluntary basis, improves transparency, stakeholder relevance, alignment with gender equality commitments. -\tIt is valuable for driving impactful pay equity actions, despite being more complex to calculate. -\tThe adjusted pay gap is the only metric truly reflecting \"equal pay for equal work or work of equal value.\"  Conclusion The views on this step differ significantly. Many find the adjusted gender pay gap metric is critical for meaningful, fair, and actionable pay equity reporting and should be retained. Others refer to the upcoming EU Pay Transparency Directive, which will mandate detailed disclosures. Until a consensus on definition is reached it does not meet EFRAGs objective of simplified and comparable reporting."]
["Survey","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Areas of improvement: -\tThe proposed amendments to ESRS S1 bring useful simplification to reporting obligations and clearer structure and may ease the burden on companies. -\tThe revised S1 improves clarity on incident reporting, training and grievance mechanisms, and the proportional thresholds for country‑level metric disaggregation are reasonable. The approach to calculating adequate wages outside the EU is more consistent, though additional guidance on local adaptation would improve reliability. -\tHowever, several respondents expressed that is no significant simplification in reporting from our perspective. -\tWhilst marginal simplification is achieved through a proposed reduction in data points, this standard remains metric \"heavy\", with a high reporting burden. -\tIt also retains metrics which are not decision useful for users of the Sustainability statement and are poorly defined, such as training and skills development. Inconsistent definition and data collection challenges for the disability metric could result in incorrect misinterpretation by readers. -\tSome datapoints, we are given the possibility to choose between narrative and table to disclose the data, which is welcomed by respondents. -\tCollective bargaining agreements datapoints require a big effort and are not sufficiently clear."]
["Survey","University of Warwick","Academia","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","University of Warwick","Academia","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","These additional data points are particularly welcome, as they provide information that is crucial for assessing a firms sustainability performance and they do not impose any unnecessary burden, as highlighted."]
["Survey","University of Warwick","Academia","United Kingdom","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University of Warwick","Academia","United Kingdom","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Afep","Business association (other than association of financial institution)","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","The use of the terms \"gross\" and \"net\" can be confusing for preparers. It would be clearer to specify when mitigation and remediation measures can and cannot be taken into account.  Furthermore, Appendix C is not clear and creates confusion because:  -It is different from the principles.  -It adds the theoretical case of information to be produced in the next reporting period (year N+1).   In practice, when producing a sustainability report, companies are always focusing on the reported period. Impacts cannot be artificially divided into different periods. Therefore, companies consider that Appendix C should be removed to avoid difficulties related to diverging interpretations.   If the \"gross versus net\" approach is maintained and to enable consistency between impacts, risks and opportunities, a gross assessment should remain the main principle, while a net approach should be possible in some circumstances according to the company's judgement. This more flexible approach seems to preserve interoperability with ISSB, which does not prescribe whether or how an entity is required to consider risk mitigation activities.   Regarding the time horizon, a distinction should be made between:  - Actual impacts: to be assessed, taking into account actions already implemented at the date of the materiality assessment. -Potential impacts: to be assessed before considering future mitigation actions ; past actions can be taken into account."]
["Survey","Afep","Business association (other than association of financial institution)","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","Quantitative reporting on anticipated financial effects is still premature given the immaturity of methodologies. Mandatory qualitative disclosure should be the baseline, with quantitative elements allowed on a voluntary basis (see option 2 for relief ESRS2 §23 a).    Therefore, §40, §41 and §42 must be subject to this option 2. "]
["Survey","Afep","Business association (other than association of financial institution)","France","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","Any simplification of the already highly complex framework should be achieved without introducing new requirements or by moving \"may\" datapoints to \"shall\" datapoint, that also exceed the Commission's mandate given to EFRAG. E2-4: Neither the definition of secondary microplastics nor the associated risk assessment along the value chain are officially established. Their impacts are not yet clearly addressed by science. Given the lack of robust and consistent methodologies to date, this item must be suppressed.   E5-4: At present, the notion of critical and strategic raw materials may evolve over time with the development of the Critical Raw Materials Act, and as the delegated acts deriving from the Eco-design for Sustainable Products Regulation are not yet approved. Companies consider this information hard to access and publish, particularly since these materials are often mixed with others. In this evolving context, this datapoint shall be inserted in the NMIG. "]
["Survey","Afep","Business association (other than association of financial institution)","France","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","With regard to remuneration, be it the pay gap or the ratio (S1-15), companies question the value of unadjusted indicators that do not provide any useful information and which, if reproduced without contextual explanation, may contribute to damaging their reputation.  The adjusted pay gap is the only metric that directly measures compliance with the principle of \"equal pay for equal work or work of equal value.\""]
["Survey","Institute of International Finance","Association of financial institutions","United States","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","We welcome the relocation of all mandatory disclosure requirements into the main body of the standards, along with the placement of application requirements directly below each relevant Disclosure Requirement and Chapter in ESRS 1.   However, some concerns remain: -\tSome \"may disclose\" datapoints remain (e.g., ESRS 1.114, 1.115) and should be reconsidered to ensure consistency in mandatory reporting.  -\tChanges to established terminology should be approached with caution, given that many undertakings are already preparing or reporting under the original ESRS. The consistent use of \"material IROs\" should be ensured across the standards, avoiding references to \"material topics,\" and wording should not alternate between \"adverse\" and \"negative\" impacts.  -\tMembers remain concerned by the wording of certain Application Requirements. Expressions such as \"shall consider\" create ambiguity, as it is unclear how \"consideration\" can be measured or audited.  More generally, IIF members believe that merely reducing the total number of mandatory data points may not necessarily result in a reduction in reporting burden. For example, in ESRS E1, companies are still required to disclose GHG emissions broken down by scope 1, 2 and 3. Previously, disclosure of the overall total (as the sum of scopes 1, 2 and 3) was also required, however the burden arises from the need for firms to source scopes 1, 2 and 3 emissions, not from calculating a simple sum.  Additionally, the merging of requirements should be considered a consolidation and not an elimination of requirements. It would also be helpful if EFRAG provided a clearly defined list of updated data points."]
["Survey","Institute of International Finance","Association of financial institutions","United States","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","We acknowledge that the proposed draft reflects some stakeholder feedback, however IIF members are concerned that proposed changes may not lead to a meaningful reduction in reporting burden in practice. Much of the reduction of data points comes from redrafting existing data points or removing voluntary ones, while the majority of mandatory data points remain, some even reappear in the NMIG or are newly introduced.  The actual realization of a simplified framework, or not, will hinge on how new concepts are interpreted (such as undue cost and burden, fair representation, materiality filter etc.). We understand that the intention is to shift the focus toward meaningful disclosures rather than process-heavy reporting. However, as currently drafted, the standards still require significant effort to explain the process behind disclosures, justify omissions, and address assurance requirements.    The remaining mandatory reporting requirements should be further assessed for decision-usefulness. For example, disclosures related to anticipated financial effects should be analyzed further (see response to Q20). Where such information may be produced, it is highly speculative, lacks reliability for current-period estimation, introduces auditing challenges, and is unlikely to be comparable between entities."]
["Survey","Institute of International Finance","Association of financial institutions","United States","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I disagree","IIF members believe that EFRAG should not review AR26 for the Amended ESRS E4. The existing ESRS 2 GDR-T provides comprehensive guidance for target-setting disclosures, and additional prescriptive application requirement could create implementation complexity without proportional benefits.   However, EFRAG should consider removing AR 5 (engagement with indigenous peoples) associated with paragraph 17 as this undermines EFRAG's stated simplification goals. If the objective is to reduce prescriptive guidance and rely on ESRS 2 GDR-T frameworks, then AR5 represents an arbitrary exception. Moreover, AR5 introduces problematic scope creep by embedding social governance mechanisms within an environmental disclosure requirement. ESRS S3 (Affected Communities) already addresses indigenous people."]
["Survey","Institute of International Finance","Association of financial institutions","United States","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","•\tS1-5 and S1-7 – IIF members recommend EFRAG to reinstate the previous threshold approach. •\tS1-15 – IIF members recommend EFRAG to edit paragraph 43: \"to allow an understanding of any gap in pay between women and men among the undertaking's employees, and to provide insight into remuneration inequality.\" The calculation text should be kept unchanged optional contextual disaggregation (e.g., by category or country) should be located in the NMIG. •\tS1-11 – The amendment that limits reporting to data that can be \"lawfully collected\" is sensible and addresses privacy constraints across jurisdictions. However, legal regimes often restrict not only collection but also the disclosure of sensitive data. IIF members recommend EFRAG to amend AR 23 to: \"This DR requires the undertaking to report only data that can be lawfully collected and lawfully disclosed.\" •\tS1-13 –  IIF members recommend EFRAG to revise AR 30 to require scheduled working days as the basis and require the inclusion of weekends/holidays only if they form part of the individual's contracted schedule. These disclosures should also be subject to an explicit materiality assessment. •\tS1-14 –  IIF members recommend EFRAG to ensure the mapping of sub-topics to disclosure requirements and their titles do not lead to misleading disclosures or metrics not representative of the matter purported to be reported. In this case, rename the Disclosure Requirement to \"Employees entitled to family-related leave\". •\tS1-16 (AR 37–AR 41) - IIF members recommend EFRAG to move AR 37–AR 41 to the NMIG. The DR in the Standard should remain narrowly focused on reporting the number of substantiated incidents of discrimination and other human rights incidents and any related material fines, sanctions or compensation (with the 'substantiated' filter preserved)."]
["Survey","FSR – Danish Auditors","Auditor","Denmark","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","In general, we welcome the objective to clarify and simplify the double materiality assessment (DMA), and we support the application of the materiality of information filter for all disclosures.    However, we do believe that there are some provisions that should be revised to provide clarity on the requirements and consistency in the application of the materiality of information.   In particular, we suggest clarifying who the users are (in particular other users) and what types of decisions they make. In particular clarification on material information for users of sustainability statements in ESRS 1, pa. 21(b) needs revision to clarify what information is necessary for them to \"understand\" material IROs, and how the entity identifies and manages them."]
["Survey","Ellen MacArthur Foundation","NGO","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","Ellen MacArthur Foundation","NGO","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Reliefs should not exceed those set under IFRS. Doing so would weaken efforts to establish a global baseline for ESG reporting—essential for ensuring a level playing field for EU companies in the global market."]
["Survey","Ellen MacArthur Foundation","NGO","United Kingdom","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","No opinion offered."]
["Survey","Ellen MacArthur Foundation","NGO","United Kingdom","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","We support the proposed changes, noting they do not introduce additional reporting burdens—particularly for water metrics. Calculating withdrawals and discharges is already required and subject to assurance. Making these implicit data points explicit enhances clarity compared to the previous ESRS, where they were optional (\"may\" disclosures). Disclosure should remain subject to the undertaking's materiality assessment. We propose that disclosure of a biodiversity and ecosystems transition plan be triggered by the identification of material impacts, dependencies, risks, or opportunities—rather than the prior existence of a plan. Otherwise, shifting from \"may\" to \"shall\" would have little practical effect, as most companies currently do not have a biodiversity transition plan and would thus have nothing to report. We also recommend clarifying that, when a biodiversity transition plan is disclosed, it should naturally reflect and reference the links to material topics addressed under other environmental and social standards. Biodiversity loss and recovery are often driven by local issues such as pollution (E2), water use and marine resource exploitation (E3), and resource extraction (E5). In particular, organisations that implement circular economy strategies, such as regenerative agriculture, benefit both nature and people. For example, by enhancing soil's ability to store carbon, regenerative agricultural practices mitigate climate change and increases farming's resilience to weather events and improves food security. https://www.ellenmacarthurfoundation.org/articles/regenerative-agriculture#:~:text=Regenerative%20agriculture%20describes%20a%20broad,to%20establishing%20cycles%20of%20regeneration.  Making these interconnections explicit would not impose additional reporting obligations but would improve coherence, foster a more holistic view of environmental impacts and responses, and help avoid a siloed or overly narrow interpretation of what a biodiversity transition plan should include."]
["Survey","Ellen MacArthur Foundation","NGO","United Kingdom","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Resource outflows   The amendments to the DRs for resource outflows do not align with the objective of this DRs. Paragraph 16 of the [Draft] ESRS E5 states DR's  relate to \"...goods and services.\" However the DRs do not relate to services.  We recommend to either Adapt / reinstate the deleted disclosure requirement under paragraph 35 [ESRS E5 - July 2023] that requires undertakings to \"...provide a description of the key products and materials [related to] the undertaking's production process, including …. circular business models\"; or Add a new DR in [Draft] ESRS E5 to require organisations to provide information about their E5-related service activities. For example, the requirement could ask for details of circular economy business models adopted by organisations e.g. rental, product as a service (PAAS) based models etc.    interaction with other ESRS  We recommend the following revisions are made to the 'interaction with other ESRS' section to strengthen connectivity with other ESRS sub-topics.  Paragraph 9a: Strengthen connectivity between circular activities and climate mitigation and climate adaptation sub-topics similar to our comments on ESRS E1. In addition, clarify the following sentence \"Collecting energy efficiency …. can lead to reduction in carbon footprint\", as circular activities go beyond energy efficiency in operations.   Paragraph 9b. We recommend not only linking resource activities to pollution-related impacts but also including examples of E5-related activities that help mitigate these impacts — for example, designing products using safe, biodegradable materials.   Paragraph 9d. We recommend the paragraph also recognise that applying circular principles can go beyond alleviating pressures on nature to help to regenerate nature (similar to our comments questions 15 and 23).    Links to ESRS S2: We recommend adding in ESRS E5 interactions with ESRS S2 topics, as E5 related activities can  increase resilience and job security beyond companies operations to their supply chain."]
["Survey","EuropeanIssuers","Business association (other than association of financial institution)","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","EuropeanIssuers is supportive of the proposed changes, as they improve readability of the sustainability statement. However we would like to acknowledge that while this is an improvement, it does not substantially reduce reporting burdens or costs for companies."]
["Survey","EuropeanIssuers","Business association (other than association of financial institution)","Belgium","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I agree","EuropeanIssuers supports the proposed relief as it addresses real challenges in collecting reliable data, avoids weak or misleading reporting, and provides flexibility until stronger methodologies are available. Transparency alone ensures continued progress without the need for time limits.   In addition, it would be valuable to permit greenhouse gas emissions to be reported using any threshold defined in the Greenhouse Gas Protocol. This would ensure alignment with the most widely recognised international framework and strengthen consistency with the ISSB's IFRS S1 and S2 Standards."]
["Survey","EuropeanIssuers","Business association (other than association of financial institution)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I disagree","EuropeanIssuers acknowledges the intention behind introducing the principle of fair presentation, but has significant reservations about its inclusion in the ESRS at this stage. Explicitly requiring fair presentation does not necessarily support simplification. On the contrary, it may reduce comparability, increase the evidentiary burden on preparers, and create additional challenges in discussions with auditors.  In financial reporting, fair presentation is clearly directed to a primary user, the investor. In sustainability reporting, however, no such primary user has been identified. Addressing \"all relevant stakeholders\" makes the application of fair presentation far more complex and could increase responsibility for both auditors and preparers, thereby increasing legal risks. This concern is heightened in the absence of an EU-wide limited assurance standard for sustainability information. Without such a standard, there is a real risk that the principle will undermine the very reliefs that were designed to reduce burdens.  EuropeanIssuers has observed diverging views on what fair presentation actually means in the context of double materiality, and what its consequences would be. These diverging interpretations make it extremely difficult to assess the practical impact of the requirement. In this respect, many companies believe it is premature to introduce the principle of fair presentation into ESRS. Before doing so, the priority should be to establish clear reliefs, adopt an EU-wide audit standard, define the primary user, and agree on a common understanding of what fair presentation entails in a sustainability context.  EuropeanIssuers therefore believes that, while fair presentation could eventually serve as a useful principle for both simplification and to further support alignment with ISSB on this aspect, however in practice the current ecosystem is not ready for its implementation. Without clarity, a defined primary user, and harmonised EU audit standards, the concept risks becoming a source of burden rather than simplification."]
["Survey","EuropeanIssuers","Business association (other than association of financial institution)","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","EuropeanIssuers welcomes EFRAG's intention to provide additional guidance for undertaking to set biodiversity targets, however under the only circumstance that they remain voluntary and under the NMIG."]
["Survey","Frank Bold","NGO","Czechia","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","It is useful that Chapter 3 addresses the question of how prevention, mitigation and remedy of impacts shall be considered in materiality assessment, but the rules could be expressed in a more simple and understandable way.    Para 34 uses a very complicated language to express a simple idea that actual impacts shall be considered as they occurred during the reporting period, and that their ex-post remediation is not relevant.   ​​​We welcome and stress the importance of the clarification that the potential impacts which require significant ongoing preventative or mitigation efforts shall be considered gross. In this regard, it would be helpful to refer to the materiality of information filters to provide companies with further guidance on how to distinguish such significant efforts from common practice and compliance measures.   The table provided in Appendix C provides more detailed information, which it would be helpful to integrate directly into the main body to ensure clarity and consistency."]
["Survey","Frank Bold","NGO","Czechia","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree","Reliefs should not go beyond those set in IFRS. Going further would undermine the objective of setting a global baseline for ESG reporting, which is important for achieving a level playing field for EU companies in a global context.   The undue cost and effort relief outlined in ESRS 1, para 87-89, is a powerful relief, which addresses virtually all situations where the undertaking may encounter practical obstacles.    Explicit emphasis on fair presentation, combined with the strengthened focus on the use of materiality of information filter, provide companies with an increased flexibility in determining meaningful content of their sustainability statements. It marks a further move away from compliance-based to principle-based approach. However, such changes imply increased responsibility for the undertaking. Implementing further reliefs would undermine this responsibility and open the doors to abuse."]
["Survey","Frank Bold","NGO","Czechia","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","ESRS, being based on the materiality principle, the CSRD requirement to disclose impacts, risks and opportunities and their management, and the general principles of the Accounting Directive, has already been subject to a fair presentation regime. Making it explicit helps to clarify it.   It provides companies with clarity on the discretion and judgement, as well as related safeguard, they are expected to exercise when applying the standards. "]
["Survey","Frank Bold","NGO","Czechia","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","In principle we agree with the achieved balance. However, we remain concerned about the following specific issues in individual standards. Our concerns are greatest for ESRS 1, which is the only standard for which we agree with the achieved balance only partially.   We are concerned about the concurrent effect of various reliefs. We are also concerned about the unintended confusion caused by a rather confusing explanation of the relationship between impacts, risks and opportunities on one hand, and sustainability topics on the other."]
["Survey","Frank Bold","NGO","Czechia","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","ESRS S1, S2, S3, S4: We would recommend adding an explicit reference to GDR-M (metrics) in the Disclosure Requirements concerning targets, in S2, S3 and S4, that is the standards that lack any metrics. In S1, we have strong reservations about the newly suggested methodology for adequate wages outside of the EEA. It would lead to misleading disclosures and add burden for companies."]
["Survey","CEAOB","European supervisory authority","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","CEAOB","European supervisory authority","Belgium","35.ESRS1_8.1."," Do you agree with the amendments of this chapter? ","I disagree","(RefCEAOB letter par9 and 10)  The CEAOB does not concur with the editorial change in ESRS1 paragraph 103. The wording used creates confusion about the scope of information which belongs to the sustainability statement, under the scope of the independent external assurance engagement mandated by the CSRD. EFRAG should avoid any doubt and make clear that even disclosures located outside the dedicated section of the management report are an integral part of the sustainability statement.  Paragraph 103 could e.g. be amended as follows to avoid confusion on the status of information incorporated by reference: \"The undertaking shall present all the disclosures required by the ESRS within a dedicated section of the management report identified as the undertaking's sustainability statement. By exception, information incorporated by reference according to the conditions prescribed in Chapter 9.3, may be located outside that dedicated section, provided that the conditions of Chapter 9.3 are met. Information incorporated by reference remains an integral part of the sustainability statement.\"","ESRS1","8.1 General presentation requirement, structure and content of the sustainability statement",""]
["Survey","CFA Institute","User Association","United States","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I partially agree and partially disagree","In principle we support the simplification of the ESRS requirements. Reporting standards, regardless of topic, need to be straightforward to implement and easy to navigate so that the preparer understands all the requirements, the assurance provider understands what they are assessing, and the user of the resulting reporting understands what they are reading.   The speed with which the original ESRS standards were developed led to challenges and disagreements in interpretation of some of the requirements, resulting in differences in approach and limiting investors' ability to compare information about material topics across companies.   The onslaught of implementation guidance on fundamental issues that EFRAG provided after the original ESRS standards were published, along with various FAQs, is further evidence that the \"user experience\" in applying the standards was inadequate. This naturally has implications for the quality of the information that's then made available to users of sustainability statements.  So, while we agree in principle with the simplification objective, we are concerned that the approach taken focuses on eliminating the burden to companies without thinking about what investors need."]
["Survey","BT4Europe - European Network of Business Travel Associations","Business association (other than association of financial institution)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree"]
["Survey","BT4Europe - European Network of Business Travel Associations","Business association (other than association of financial institution)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","BT4Europe - European Network of Business Travel Associations","Business association (other than association of financial institution)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree"]
["Survey","BT4Europe - European Network of Business Travel Associations","Business association (other than association of financial institution)","Belgium","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Witten/Herdecke University","Academia","Germany","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","I welcome the removal of the duplications between the cross-cutting and topical standards and support the emphasis on general disclosure requirements.  However, I have two critical concerns. First, the original DR in environmental standards concerning screening of sites in materiality assessment were replaced by an application requirement to ESRS 2 IRO-1. This in effect makes transparency on this aspect optional. Consideration of local context is a key element of an appropriate materiality assessment. This should be both recognised in Chapter 3 of ESRS 1, and in ESRS 2 IRO-1, which should include an explicit datapoint on how the undertaking screened its locations and value chains. I welcome that E standards provide a clearer reference on the importance of disaggregation of disclosures, but this can only be done well if locations are properly screened. Second, I strongly recommend adding an explicit reference to the disclosure of relevant, entity-specific metrics directly in S standards. The fact that S2, S3 and S4 do not include any metrics and the anticipated sectoral standards which would have provided such metrics will not be adopted, shift the expectations for disclosure of metrics for S topics to entity-specific disclosures.   As highlighted by the Danish Institute for Human Rights, a leading National Human Rights Institute on business and human rights and reporting, adding the reference to metrics to disclosure requirements SX-4 on targets would improve consistency between the topical and the cross-cutting standards and acknowledge the common use and disclosure by companies of metrics relevant to their social sustainability impact management and progress. This addition would ensure that preparers better understand the ESRS expectations in this regard, whilst not adding any new obligations or datapoints"]
["Survey","Witten/Herdecke University","Academia","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","I support the proposed changes and agree with the removal of 'may disclose' elements, because their status has been causing confusion. However, they do not need to be all removed to NMIG. Where they provide useful examples of disclosures, they could be included directly in the standards as \"examples\". This is particularly the case for the topics for which the reporting practice is evolving, such as Biodiversity and ecosystems. This would make it easier for first-time preparers to understand what kind of information is likely to be relevant and provide a basis for the standardization of metrics. Having to consult another document, such as NMIG, is adding an unnecessary hurdle. The language and therefore understandability of the standards have been considerably improved, however in ESRS 1 especially there is still much to be done in this regard."]
["Survey","Witten/Herdecke University","Academia","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","I agree with these changes, agreeing that the suggested changes do not add a new burden.  This is particularly the case for the water-related metrics. In order to disclose the water consumption, the undertaking already has to calculate withdrawals and discharges, and such calculation and therefore the underlying data is subject to the assurance. Moving these implicit datapoints to the forefront as explicit data points makes the disclosure requirement clearer, compared to the previous ESRS where some of these datapoints were framed as \"may disclosures\". Whether or not these individual datapoints are to be disclosed is correctly subject to materiality of the information filter applied by the undertaking."]
["Survey","Witten/Herdecke University","Academia","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Witten/Herdecke University","Academia","Germany","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Witten/Herdecke University","Academia","Germany","33.Glossary.","Glossary:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany","22.","Reduction in the number of mandatory and voluntary datapoints The Amendments have realised a substantial reduction in the number of mandatory (-57%) and voluntary (-100%) datapoints, described in the Basis for Conclusions (BfC), Appendix 3. The Explanatory Memorandum (page 6) specified that “the revision of the Delegated Act will substantially reduce the number of mandatory ESRS datapoints by (i) removing those deemed least important for general purpose sustainability reporting, (ii) prioritising quantitative datapoints over narrative text and (iii) further distinguishing between mandatory and voluntary datapoints, without undermining interoperability with global reporting standards and without prejudice to the materiality assessment of each undertaking.” To achieve this objective, EFRAG undertook a systematic review of the datapoints, to eliminate the least relevant, i.e. those that are not strictly necessary to meet the disclosure objectives. Most of the deleted datapoints stem from the narrative PAT disclosures, where a less prescriptive and more principles-based approach has been implemented. Therefore, most of the deletions refer to narrative datapoints. In the context of such a systematic review, merging two distinct datapoints was not considered as a reduction. Do you agree that the proposed reduction in “shall disclose” datapoints (under materiality) strike an acceptable balance between burden reduction and preserving the information that is necessary to fulfil the objectives of the EU Green Deal?","I disagree"]
["Survey","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany","22.ESRS2","Comments on deleted datapoints in ESRS 2","I disagree","We acknowledge and welcome the improved structuring and consolidation of the ESRS requirements. The clearer separation and grouping of datapoints, especially the removal of voluntary datapoints and the streamlining of narrative PAT disclosures, enhances the usability of the standards.  However, we would like to emphasize that the reduction in the number of datapoints does not necessarily translate into a proportional reduction in the substantive reporting scope or effort.   In our view, the overall scope and complexity of the disclosures remain largely unchanged.  Many changes seem to be cosmetic without changing the underlying substance of the disclosure requirements.  The deletion of datapoints primarily affects how requirements are presented, not what is required. This means that preparers will still need to collect and disclose a substantial amount of data, and the core reporting obligations are largely preserved.   We do not expect a significantly reduced reporting volume under the amended ESRS. Instead, the changes may help reduce effort in documentation and coordination with auditors. For example, the introduced options for burden reliefs may simplify internal discussions and reduce the need to justify the omission of non-material items. It is important that this distinction is clearly communicated: while the number of datapoints has decreased, the underlying disclosure obligations remain intact. This will help manage expectations and avoid misinterpretations regarding the actual simplification impact of the amendments.  Moreover, we do have concerns regarding the new mandatory disclosure requirements that have been introduced and would suggest deleting them all to fulfill the purpose of the revision of the ESRS."]
["Survey","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","We strongly disagree with the introduction of new mandatory datapoints as this will result in a significant burden increase. In particular:   E5-4: Information on the percentage of total weight that are critical and strategic raw material is considered highly sensitive information which should not be part of sustainability reporting disclosure. Further, there are other new (or significantly amended) mandatory datapoints in the context of E5-4 which are not mentioned by EFRAG in this question (E5-4-31a and b) which may cause additional efforts especially since there is no clarification whether a net-approach may be followed here (e.g. omit disclosure on clippings/scraps for manufacturing companies)."]
["Survey","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The willingness for practical considerations related to DMA is well perceived, however due to the unclear, adjusted DMA approach (e.g. mixed sub-topic/sub-sub-topic level, impracticable solution for the net evaluation of IROs) and due to the high level of disaggregation required, the resulting reporting would probably not contributing to the core objectives of the European Green Deal."]
["Survey","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The ESRS revisions are not satisfactory overall. Although some areas have been shortened and disclosure obligations have been eased, some data points have been added or tightened further. We do not see any general simplification of the disclosure requirements. There is currently no balance. The European Green Deal can be better pursued with fewer but more precise requirements."]
["Survey","Schwanhäußer Industrie Holding GmbH & Co KGGroup","Preparer (non-financial preparing a sustainability report)","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","Companies might already habe a CatNat analysis of their assets for insurance purposes. On that basis, we consider the quantitative modelling foreseen in ESRS E1 paragraphs 40 (a)–(d) as redundant and not decision-useful. Deriving global estimates for asset damages or revenue at risk would involve multiple layers of assumptions and high uncertainty, without improving risk management or stakeholder insight.  We therefore recommend that companies be allowed to rely on existing, insurance-based or equivalent analyses to meet the disclosure objective, and that qualitative descriptions of exposure and resilience be deemed fully compliant for preparers of our size and structure.",null,null,""]
["Survey","Schwanhäußer Industrie Holding GmbH & Co KGGroup","Preparer (non-financial preparing a sustainability report)","Germany","22.S1","Comments on deleted datapoints in ESRS S1","I partially agree and partially disagree","Yes, with conditions. We welcome the substantial reduction in mandatory datapoints, which meaningfully lowers effort for Wave-2 preparers while preserving core objectives. To ensure the intended simplification materialises in practice, we ask EFRAG to: (i) confirm that qualitative, decision-useful disclosures are acceptable where robust quantification is not feasible; (ii) prevent re-prescription via Application Requirements or assurance expectations; (iii) publish a clear mapping from deleted to retained datapoints to avoid \"shadow\" re-introductions; and (iv) most importantly claerly reaffirm and make it absolutely clear that information materiality is the decisive filter."]
["Survey","ITALIAN FOUNDATION FOR BUSINESS REPORTING (O.I.B.R.)","NGO","Italy","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","Despite many commendable specifications and the effort to make the sustainability statements closer to financial statements (\"fair presentation principle\"), there are still points for consideration.   An important general orientation should be that of diminishing the possible friction points between companies and auditors.  Another \"polar star\" should be the consistency with the indicators used by hard scientists to determine the planetary boundaries and their possible trespassing. A further important general element to take into account is the consistency with other indicators and onformation required in other parts of the EU legislation, such as EcoLabel, EcoDesign, and Waste and Circularity. The impression is that sometimes these diverse legislations do not speak to each other, and require disclosures to companies that are not always aligned.   Looking more at detailed provisions linked to DMA, the definition of information materiality should be better explained. In particular, the points a) and b) can be more adequately amalgamated to avoid possible confusion. The introduction of decision usefulness is fine (point a), but its relationship with the \"understanding\" (point b) should be given a better thought.  The choice left between top-down or bottom-up approach can be easily a source of disagreement between companies and auditors. If technically both approaches produce the same results (as stated in AR 17/ESRS 1), probably it is worth considering to give prevalence to one of the two.  In interoperability terms, we would like to note that, while the concept of non-obscuring is aligned in principle with the ISSB Standards, the ESRS draft introduces additional requirements and ambiguities that may: -\tReduce clarity for investors (ESRS draft does not explicitly require that investor-relevant information be distinguished from broader stakeholder disclosures, potentially reducing interoperability), -\tIncrease reporting complexity, and -\tCreate potential conflicts with IFRS Industry-Based Guidance, which is EFRAG recommended for entity-specific disclosures."]
["Survey","ITALIAN FOUNDATION FOR BUSINESS REPORTING (O.I.B.R.)","NGO","Italy","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","In the previous responses, we have already provided detailed examples of potential lack of interoperability with IFRS SUstainability standards, and namely in responses # 11, 17, and 19.  We would like to point out another technical issue in interoperability terms which should be considered.  As to GHG emissions, the draft simplified ESRS goes further by mandating the financial control boundary for GHG measurement.   In addition, it introduces a secondary requirement: if the financial control approach does not provide a fair presentation, Scope 1 and 2 emissions should also be disclosed on an operational control basis, as defined in the GHG Protocol.  This dual requirement does not align with the GHG Protocol (required by IFRS S2), which stipulates that entities should adopt a single approach (equity share, operational control, or financial control).   As a result, entities applying both ISSB Standards and ESRS may face unnecessary complexity and duplicative work, having to reconcile different approaches to emissions measurement.  Aligning ESRS with the IFRS S2 approach - by simply referencing the GHG Protocol and allowing entities to choose among the established methods - would reduce the risk of inconsistency across the GHG Protocol, ESRS, and IFRS S2, while also easing the compliance burden for companies."]
["Survey","CCOO","Trade union","Spain","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","It is important that companies report not just their net impact – the gross impact should be reported, and the recommended text preserves this principle."]
["Survey","CCOO","Trade union","Spain","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I disagree","These combined reliefs overshoot the balance between transparency and cost/effort and risk enabling green/social washing. At a minimum, there should be a time limit introduced for these reliefs on value chain metrics"]
["Survey","CCOO","Trade union","Spain","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","It is essential that financial institutions disclose absolute targets to assess how their strategies align with the economy-wide transition to net zero. Absolute targets are relevant for users of sustainability statements and for understanding the real-world climate impact of financed activities. While intensity measures provide insights into efficiency, they can mask rising absolute emissions in growing portfolios or sectors.   Granting an exemption would also undermine fairness in a sector-agnostic standard. Other industries could equally argue for exceptions based on their own difficulties, reducing comparability across sectors. Moreover, absolute financed emissions are already recognised in existing standards and regulations: the SBTi financial sector net-zero standard, the UNEP FI/NZBA recommendations, and EU SFDR all require or encourage absolute emissions disclosure. Exempting banks would risk misalignment and reduce the usefulness of reported data for stakeholders, including asset owners who depend on it for their own disclosures."]
["Survey","CCOO","Trade union","Spain","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","The proposed \"top 10\" threshold for the reporting of country-level information for employee headcount, collective bargaining and social dialogue is a significant improvement over the current 10% employment threshold. Country-level information needs to be reported in more detail, and on other metrics as well, in order to have more transparency on the distribution of impacts across countries. In the metrics, voluntary datapoints need to be reinstated as well as the datapoints on gender breakdowns, workforce age distribution, etc. detailed above need to be reinstated. The proposed new methodology for adequate wages outside of the EU also needs attention, and the transition language for EU member states needs to be reinstated, since the Adequate Minimum Wage Directive has not been implemented in some Member States. We would also like to reiterate our longstanding demand for including franchise workers in the S1 definition of own workers, as well as the need for sector-specific standards to supplement the Set 1 sector-agnostic standards."]
["Survey","The Institute of Chartered Accountants of Scotland (ICAS)","Auditor","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","We agree with the proposal to give more prominence to the materiality of information as a general filter that drives the prioritisation of sustainability matters to be reported (and otherwise managed).  This approach facilitates the better allocation of resources and ensures important matters are not obscured.  We believe that reporting per double materiality gives a more comprehensive account to more investors as well as other stakeholders of a reporter's progress and plans.   We have heard that some reporters have found the double materiality assessment (DMA) process to be useful and beneficial.  The DMA should provide guidance and not be prescriptive, so that reporters can interpret and apply the process to their specific business operations."]
["Survey","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I partially agree and partially disagree","Overall we welcome the gross vs net approach. Existing remediation, mitigation, an prevention measures are a part of the materiality assessment and reporting determination and should not require extensive new evidence. Furthermore, the question of gross vs net impact remains dependent on the individual company.  Despite EFRAG's efforts to clarify the treatment of remediation, mitigation, and prevention actions in the DMA, the current guidance is overly complex and needs substantial revision to avoid an excessive reporting burden. For actual impacts, a gross approach is appropriate, as stakeholders need to understand both the original impact and subsequent remediation measures. However, for potential impacts, the current framework requires significant revision. For example the guidance's treatment of 'significant ongoing mitigation actions' and the ambiguous requirement for 'supportable evidence' risks inconsistent interpretation by auditors and could lead to excessive documentation requirements. Instead, the guidance should distinguish between 'measures' (existing safeguards) and 'actions' (new initiatives) to clarify reporting obligations. Existing prevention and mitigation measures should be considered part of the baseline assessment without requiring extensive new evidence gathering. The current guidance also creates confusion through apparent contradictions between Appendix C and the main text, particularly regarding the treatment of ongoing mitigation actions. EFRAG should remove Appendix C or at least substantially simplify it to provide clear, flexible and practical guidance. Finally, sustainability reporting should align with financial reporting principles regarding materiality assessment and granularity of information. This would ensure consistency while reducing unnecessary reporting burden."]
["Survey","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I partially agree and partially disagree","Despite EFRAG's efforts to reduce disclosure requirements for anticipated financial effects, the remaining requirements in Amended ESRS E1 (Paragraphs 40, 41, 42) continue to pose significant feasibility challenges and potential risks for reporting companies. The granularity of required disclosures, such as monetary amounts and percentages of assets at material physical or transition risk, locations of key assets, and revenue from business activities at material physical risk, often exceeds the level of detail currently provided in financial statements. This discrepancy creates potential inconsistencies between financial and sustainability reporting, which could lead to confusion among stakeholders and complicate the assurance process. These requirements are subject to high estimation uncertainty, lack clear accounting guidance, and may reveal business-sensitive information. For global companies, allocating revenue by physical asset location may not align with how the business is managed or measured. Moreover, the disclosure of such detailed information raises competitive concerns and may require significant changes to existing data collection and reporting systems. We caution against mandatory disclosures based on climate scenario analysis, as scenario planning is a stress-testing tool, not a forecast. Treating these scenarios as predictions could mislead stakeholders and expose companies to reputational or legal risks. Given these concerns, we recommend aligning the ESRS E1 requirements more closely with ISSB standards and existing financial reporting practices. We support a less prescriptive approach that allows companies to focus on material information relevant to their specific business model and industry.  Furthermore, we recommend that EFRAG adds language to acknowledge the non-predictive nature of scenario analysis and provide safeguards against misinterpretation. The standards should also explicitly allow companies to protect commercially sensitive information while still demonstrating robust risk management practices.",null,null,""]
["Survey","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I partially agree and partially disagree","EFRAG's intention to align with IFRS sustainability standards through the incorporation of 'fair presentation' principles is positive. However, Amcham EU members have mixed views about this mandatory principle. The concept of fair presentation could help guide companies toward stakeholder-relevant information and mitigate excessive reporting by reducing the risk of a compliance checklist approach. However, its implementation in sustainability reporting raises also concerns, particularly regarding impact materiality, where established reporting practices are still evolving and presents unique challenges not found in financial reporting. Sustainability data is often forward-looking, qualitative, and judgment-based, lacking the evidentiary rigor of financial data. This creates uncertainty about what constitutes a 'complete and faithful' representation, especially in impact materiality assessments. Companies have mixed opinions about this being a principle that applies broadly. Making fair presentation a legal requirement may inadvertently increase regulatory enforcement complexity and audit costs without demonstrably improving reporting quality. The absence of clear thresholds, safe harbours, or practical examples may lead companies to over-disclose to mitigate perceived regulatory or assurance risks. If EFRAG proceeds with mandatory fair presentation, provide detailed guidance on its application in the context of impact materiality, while establishing clear parameters for what constitutes adequate disclosure. The framework should be aligned with the ISSB Standards' approach, where fair presentation builds upon compliance requirements, and specific safeguards should be developed to prevent excessive disclosure requirements. Alternatively, companies could be allowed to voluntarily adopt fair presentation standards while maintaining mandatory disclosure of the assurance standard used. This approach would preserve the benefits of fair presentation while avoiding potential complications in implementation and assurance, particularly during this evolving phase of sustainability reporting."]
["Survey","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","The current definitions of classified and sensitive information are overly narrow and should be expanded to explicitly include trade secrets as defined in EU Directive 2016/943. While 'secret information' is addressed in paragraph 99, this only applies to strategy and action plans. Companies should be protected from disclosing any trade secrets, even if deemed material. Additionally, the value chain scope for impact materiality assessments should be limited to entities with direct contractual relationships. Large multinational organizations face significant practical challenges in tracking and assessing impacts beyond direct relationships, particularly given inconsistent data availability and limited influence over extended value chain entities. The current requirement to assess impacts across the entire value chain creates unrealistic expectations and potential inaccuracies in reporting."]
["Survey","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree"]
["Survey","UHY ECA Audyt Sp. z o.o.","Auditor","Poland","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Over-simplification can undermine the quality of reporting. We understand that some companies may find it difficult to estimate the financial impact at the outset, but the possibility of limiting oneself to qualitative descriptions alone is too broad and risky. ESG reporting without figures becomes too general and detached from the realities of management. Companies, and especially owners and management boards, make decisions based on financial data. If they do not see the costs associated with environmental penalties, energy losses, resource waste, or climate risks, they will not take these areas seriously. The relief should only apply to companies that demonstrate real difficulties in obtaining numerical data, and only temporarily. There should be an obligation to indicate a plan for obtaining complete data, e.g., within 1–2 years. Non-financial reporting must cease to be \"soft\"—if it is to support management, it must be based on hard facts, not just declarations."]
["Survey","UHY ECA Audyt Sp. z o.o.","Auditor","Poland","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","The division of plastic microbeads into primary and secondary – a valid simplification that will allow for better visualization of information on microbeads.  A clear distinction between primary and secondary microplastics and a more precise definition will greatly facilitate the work of entities that are required to assess microplastic emissions from products or packaging. However, the ESRS still does not specify a methodology for estimating the level of plastic microbead emissions. This may result in the use of estimates that are difficult to compare."]
["Survey","UHY ECA Audyt Sp. z o.o.","Auditor","Poland","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We take a negative view of the abandonment of sector-specific standards. The lack of sector-specific standards results in overly general reporting that fails to take into account the specific nature of the industry. The implementation of EFRAG sector standards (or the requirement to apply IFRS S2 sector standards) reduces the burden on entities (entities do not have to carry out DMA in this regard, as most of the data is already collected by entities) and will benefit users of sustainability statements."]
["Survey","Association of Ethical Shareholders Germany","NGO","Germany","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","Yes, as stated before: A minimum of figures needs to be reported in a uniform manner. There should be no question of interpretation as to whether a company has failed to comply, partly complies or complies with its minimum reporting obligations."]
["Survey","Association of Ethical Shareholders Germany","NGO","Germany","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree","This does not represent an additional burden, but rather helps to focus attention on the relevant aspects. Companies should treat voluntary disclosures in a similar manner in other thematic contexts and report on relevant IROs in a comprehensible manner in accordance with their DMA."]
["Survey","Association of Ethical Shareholders Germany","NGO","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Association of Ethical Shareholders Germany","NGO","Germany","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","eftec","Preparer (non-financial preparing a sustainability report)","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","There is not sufficient emphasis on dependencies.  The reporting should encourage companies to think about their dependencies, directly or through their value chain, on all of nature's services (not just as input to production). Thinking about dependencies encourages businesses to understand in what ways their financial sustainability depends on nature. This understanding incentivises businesses to invest in nature to secure financial returns. Focusing on impacts only leave nature in the regulatory box - with the result of lesser engagement by Boards and wanting to resolve impacts at the least cost possible, i.e. ESRS will not change the status quo. Also leaving out dependencies means ESRS will be out of sync with TNFD and ISO14054"]
["Survey","eftec","Preparer (non-financial preparing a sustainability report)","United Kingdom","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","Data availability can be a big challenge. And relief for data gaps should be granted. However, limiting risks or any other part of the analysis and reporting to qualitative only is damaging. Qualitative assessment of environmental impacts, dependencies, risks and opportunities condemn these issues to isolation. We want ESRS reporting to bring nature to the heart of business and at the heart of business, qualitative assessment has no presence other than lip service. This is a major problem of the revisions and severs the link between financial and non-financial reporting (including natural capital accounting)."]
["Survey","Euromines","Business association (other than association of financial institution)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","The simplified approach provides more flexibility, in particular the possibility of an top-down approach."]
["Survey","Euromines","Business association (other than association of financial institution)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","Anticipated financial effects as such are speculative as such - and thus not providing added value. Future-oriented statements that cannot be substantiated are not in the remit of responsible investor-relations and will lead to uncertainty as well as difficulties to audit. Rather than portraying a realistic image, it may create misleading impressions. Investors do have already access to risk-related disclosures so that we strongly recommend to remove the public disclosure of anticipated financial effects."]
["Survey","Euromines","Business association (other than association of financial institution)","Belgium","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree"]
["Survey","Euromines","Business association (other than association of financial institution)","Belgium","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Euromines","Business association (other than association of financial institution)","Belgium","33.S_4.","ESRS S4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","AMICE","Insurance","Belgium","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree","We welcome the increased flexibility introduced by the amendments to the organization of the sustainability reporting, particularly the inclusion of an 'executive summary', the option to incorporate appendices, also to include EU Taxonomy tables, and the emphasis on non-duplicative reporting. This flexibility enhances the ability of organizations to structure their reports in a more efficient and tailored manner, aligning with the diverse needs of stakeholders.  Additionally, we recognize and appreciate the clarification of the 'connected information' concept in ESRS 1. This clarification is instrumental in reducing fragmentation and repetition between sustainability disclosures and broader corporate reporting. By fostering better connectivity, it ensures a more coherent and integrated approach to reporting, which will undoubtedly enhance the usefulness and comprehensibility of the information presented to stakeholders."]
["Survey","AMICE","Insurance","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 2","As a matter of priority, considering the complexity and uncertainty both in the calculation and in the reputational impact in the reporting, we ask EFRAG to delete disclosure requirements on anticipated financial effects from the ESRS. Data that relies heavily on estimates and is subject to significant uncertainty does not offer reliable insights for investors or other users, due to its potential variability. Premature disclosure of such information may not only mislead stakeholders but also expose companies to reputational and legal risks stemming from misinterpretation. Hence, should the disclosure requirement relating to anticipated financial effects be maintained in ESRS, AMICE is of the opinion that Option 2 (qualitative information) is the preferred option.  Option 1 entails significant uncertainties due to numerous interactions with other elements, which may result in the dissemination of inaccurate information to the public and end users. The information remains valid for a maximum of five years; however, years four and five are particularly difficult to assess with accuracy. Moreover, requesting an assessment based on a two-year timeframe is highly limited and would fail to account for all global factors that could influence the outcomes."]
["Survey","AMICE","Insurance","Belgium","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I agree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","We agree that financial institutions should be exempted from disclosing absolute GHG emissions targets when only intensity-based targets have been established. Insurer´s emissions are predominantly indirect and stem from investment and underwriting activities rather than direct operations. In such cases, estimating absolute emissions targets necessitates extensive assumptions and complex modelling across diverse portfolios, resulting in outputs with limited reliability, auditability, comparability and minimal added value for users."]
["Survey","AMICE","Insurance","Belgium","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See our general comments."]
["Survey","AMICE","Insurance","Belgium","33.S_3.","ESRS S3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","See our general comments."]
["Survey","Die Bürokratiemonster","NGO","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I agree","This applies to all questions that follow. The pressure to simplify the ESRS was completely exaggerated by scaremongering on the burden of reporting. All the while reporting against the ESRS is still much less of a burden than doing financial reporting. The questionnaire is hence biased as the option that there was too much of a simplification is not provided.  4. Must be reverted, as it non-material serves no apparent purpose except to distract from what matters.    5. We commend the focus on fair presentation framework and strongly recommend for EFRAG to maintain this focus in upcoming debates.  6. Is unacceptable. There is no obvious history of overreporting against the ESRS. The ESRS cover a much wider range of topics than financial reporting, yet sections of management reports on non-financial information are still shorter than those with financial information.   7. Reinstate the granularity, as they serve as helpful guidance.  8. Companies must not be allowed to aggregate to the extent that it obscures information."]
["Survey","Die Bürokratiemonster","NGO","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Die Bürokratiemonster","NGO","Germany","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Across all topical standards a reference to ecological budgets needs to be maintained, so that it is clear whether the targets are context-based or based on hot air.   Agreed: \"While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN.\""]
["Survey","Die Bürokratiemonster","NGO","Germany","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I disagree"]
["Survey","Die Bürokratiemonster","NGO","Germany","33.S_1.","ESRS S1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","TIM s.p.a.","Preparer (non-financial preparing a sustainability report)","Italy","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Status of NMIG to be clarified"]
["Survey","TIM s.p.a.","Preparer (non-financial preparing a sustainability report)","Italy","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree"]
["Survey","TIM s.p.a.","Preparer (non-financial preparing a sustainability report)","Italy","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree"]
["Survey","Former - Capgemini Technology Services Pvt Ltd","Other - please specify (required)","India","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Former - Capgemini Technology Services Pvt Ltd","Other - please specify (required)","India","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I would like to skip this question and provide my feedback in Part 3"]
["Survey","Former - Capgemini Technology Services Pvt Ltd","Other - please specify (required)","India","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Former - Capgemini Technology Services Pvt Ltd","Other - please specify (required)","India","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I agree"]
["Survey","Former - Capgemini Technology Services Pvt Ltd","Other - please specify (required)","India","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","DIGITALEUROPE acknowledges the improvements made to simplify the Double Materiality Assessment process, particularly welcoming the flexibility to choose between top-down and bottom-up approaches. The clarification that companies need not assess every possible impact, risk, and opportunity (IRO) across their entire value chain represents a positive step toward more focused and decision-useful reporting. However, several critical concerns remain. The simplification efforts, while appreciated, do not go far enough. The standards maintain numerous data points that are not subject to the DMA assessment, i.e. data points that must be reported on even if they are not material for companies. A minimum of three years is necessary for companies to prepare their reports and assurance, and EU guidelines should clearly define reasonable limits on auditors' documentation demands. The Impact Materiality Scoring remains overly prescriptive. Despite helpful clarifications, the detailed documentation requirements may lead to excessive auditor demands, particularly as some DMA assessments are based on long-term, forward-looking estimations and assumptions. The current proposal sets documentation requirements at an unreasonably high level, and we recommend removing explicit documentation requirements from the standards to prevent increased burden from auditors. Even if the intention is to reduce workload, defining and requiring such level of documentation could lead to even increased burden, as taking into account all situations, conditions, and information available when defining reasonable/ supportable evidence is impractical. While the proposed aggregation and disaggregation guidance is welcomed, it requires revision. Although companies' discretion in determining appropriate levels is appreciated, the provided examples could be interpreted as mandatory requirements. We strongly recommend further alignment with ISSB standards, making disclosures and assessments for positive impacts and opportunities voluntary, and eliminating examples for aggregation/disaggregation to prevent misinterpretation as requirements."]
["Survey","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","DIGITALEUROPE supports maintaining flexibility in the disclosure of anticipated financial effects and recommends leaving quantification as a voluntary option. Qualitative disclosures on anticipated financial effects significantly reduce the burden compared to mandatory quantitative assessments, which are highly resource-intensive and speculative. The relief should remain in place, as due to insufficient guidance from accounting standard boards, compliance costs could rise significantly, and the comparability of disclosures might decrease, inadvertently reducing their decision usefulness. We note that estimating the financial implications of impacts, risks, and opportunities is highly uncertain and challenging due to additional net costs beyond normal business operations and the sensitivity of information that relies on non-public business growth projections.  While companies may face fundamental challenges in providing qualitative statements as these still require quantitative assessments, DIGITALEUROPE notes that qualitative disclosures on anticipated financial effects significantly reduce burden.  Therefore, DIGITALEUROPE proposes the indefinite removal of all phased-in disclosures related to anticipated financial effects. If requirements are maintained, we recommend allowing companies to provide qualitative information instead of quantitative data for current financial effects, as this would better balance the needs of stakeholders with the practical challenges faced by reporting companies."]
["Survey","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","While we welcome the removal of requirements to disclose effects across short, medium, and long-term time horizons, the remaining requirements still pose significant feasibility challenges. We identify three key concerns with the current requirements. First, the disclosure of monetary amounts and percentages of assets at material physical/transition risk before considering climate change adaptation actions is problematic due to estimation uncertainty and lack of accounting guidance. This is particularly challenging when considering assets with insurance policies or assessing income statement impacts, where multiple factors such as policy changes, business growth, and infrastructure development create significant variability. Second, requiring disclosure of key assets' locations at material physical risks raises business sensitivity concerns. Third, the requirement to report monetary amounts and percentages of revenue from business activities at material physical risk is impractical for global companies that don't track revenue by physical asset location. Furthermore, we note that material financial impacts are already covered under IFRS accounting standards. As most companies apply the IFRS accounting standards, the proposed requirements not only create potential redundancy but also go beyond ISSB requirements, potentially undermining international alignment efforts. It should be noted that EFRAG explicitly states that cross-referencing to other parts of the management report including the financial statement should be increased.  We recommend that commercially sensitive information should not be required, and when sustainability-related financial effects cannot be separately identified from business activities, companies should have the option to omit metrics with appropriate explanatory disclosures.",null,null,""]
["Survey","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I partially agree and partially disagree","DIGITALEUROPE supports the deletion of the voluntary adjusted gender pay gap datapoint as it aligns with the objective of reducing reporting burden while maintaining the mandatory unadjusted metric for basic comparability across entities. However, we note that the adjusted gender pay gap often provides more meaningful insights, as it compares gender pay differences based on the same job type, better reflecting the principle of equal pay for equal work. The current unadjusted pay gap, which only compares men and women overall, may present a distorted picture, particularly in certain industries. This distortion is further amplified when benefits are included in the calculation, as these are typically managed at country level independently of gender. While supporting the simplification effort, DIGITALEUROPE recommends that companies retain the flexibility to report adjusted gender pay gap data voluntarily when it provides more relevant information for their specific context."]
["Survey","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I disagree","[E5-31, E5-36 and E5-37 references] DIGITALEUROPE recommends that all new disclosure requirements introduced through this revision to be deleted as they contradict the simplification spirit of this exercise. For instance, disclosure requirements E5-31, E5-36 and E5-37 are unclear or sometimes even problematic. For instance, E5-37e seems problematic should the estimation of the waste breakdown is no longer be allowed and will likely lead to various interpretations and reporting practices, especially as less companies would be in scope of the CSRD and have less rights on requesting data to companies outside of scope. [E5-4] Not only is the information on total weight based on individual materials difficult to obtain but disclosing key strategic and critical material is sensitive information."]
["Survey","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"•\tFlexibility for global targets and data - when programs are managed globally and EU disaggregation is only for reporting purposes •\tRemove mandatory topic-based disclosures not subject to materiality - no topics issues should be required to be reported by all  •\tAlso no comply-or-explain mechanism e.g. with regard to climate change or targets etc that are not existing. •\tMake CapEx/OpEx disclosures optional - burdensome to calculate, focus on impact rather than spend  •\tReduce duplication with existing EU regulations that ask for the same info as CSRD (i.e. gender pay) and that apply to most companies."]
["Survey","Finance Watch","NGO","Belgium","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","Finance Watch highlights that climate transition plans  are a key element of the CSRD reports. The preservation of most datapoints under ESRS E1-1 (Transition plan for climate change mitigation) and ESRS E1-4 (Targets related to climate change mitigation and adaptation) is therefore welcome. However, Finance Watch highlights the complexity to compare transition plans reported under CSRD and, in some cases, to understand whether the reporting company considers that it has a CSRD-relevant transition plan . In that regard, Finance Watch welcomes the EFRAG proposition to keep the disclosure requirement for the undertaking to indicate whether and, if so, when it will adopt a transition plan for climate change mitigation, if it does not have one in place. Yet, additional details on the target setting methodologies, the baseline year and the granularity should be considered to support comparability.  The limited comparability of transition plans is also explained by the absence of clear format for reporting companies to disclose their transition plan. Based on Finance Watch study (as referenced above), some companies only disclose their transition plan and GHG emission reduction targets in a free text format, which makes it difficult for users (banks/finance providers, investors, researchers and civil society actors) to read the report and for institutional investors to reuse the information. Some undertakings disclose their targets in more retail-friendly illustrative representation. Finally, some undertakings disclose their targets in a table format, which can be more easily processed by institutional investors. As a result, it is still difficult to compare companies' transition plans to identify more ambitious actors, compare and assess progress. Finance Watch therefore recommends the EFRAG to complement the transition plan disclosure requirements with a required illustrative representation of GHG emission reduction targets and a mandatory tabular representation."]
["Survey","Revisorforeningen","Other - please specify (required)","Norway","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We welcome the relief for undue cost or effort mechanism, but believe further clarification is necessary to ensure consistent application and avoid loss of relevant information."]
["Survey","Revisorforeningen","Other - please specify (required)","Norway","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","The rationale for moving these \"may\" to \"shall\" data points is that 'they do not add new obligations, as they refer to an already existing disclosure objective'. While we do not disagree, this approach does not seem to have been applied consistently to all DRs. The approach taken for these additional data points seems to clarify implicitly the status of the DR objectives and that the overarching principle is that they must be met. On the other hand, for other DRs the opposite approach seems to have been taken.    On the specific proposal to require mandatory disclosure of a transition plan for biodiversity and ecosystems if such a plan exists, we are concerned with difficulties in assessing whether an undertaking's plan would be considered a transition plan (as opposed to an extension of strategic policies, actions and targets). If mandating disclosure, we think it is important that the standards include characteristics necessary to determine what constitutes a biodiversity transition plan."]
["Survey","Shell","Preparer (non-financial preparing a sustainability report)","United Kingdom","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I disagree","Overall, there has been some simplification to the DMA process. However, some revisions have not simplified the process and may even lead to increased complexity. This is particularly true of the gross vs net approach and the introduction of Appendix C, further described in our response to question 12).   For financial materiality, it is important that any requirements for the identification and assessment of material matters are fully aligned and consistent with internationally recognised financial reporting standards such as IFRS. We therefore recommend removing or fully aligning any financial reporting requirements with IFRS. In addition, we see an opportunity to further align the process for determining financial materiality and anticipated financial effects with the ISSB standards. For example, the text in ESRS 1 AR15(a) stating \"in assessing risks and opportunities for materiality, the undertaking shall consider their contribution to financial effects in the short, medium and long term based on scenarios/forecasts that are deemed likely to materialise\" is not aligned with IFRS S2 15-21 and could be revised or removed to improve interoperability. It is important to note that scenarios are a process for identifying and assessing a potential range of outcomes of future events under conditions of uncertainty and they are not intended to be forecasts or predictions of likely future events or outcomes."]
["Survey","Shell","Preparer (non-financial preparing a sustainability report)","United Kingdom","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Where robust, principles-based standards are developed with high standards of due process, we see limited need for the creation of or reference to additional guidance. We believe clear and consistent principles-based standards are the best way to ensure adherence to disclosure requirements and provide clarity to preparers and assurance providers. As such, we believe that the EU should limit references to and use of guidance materials as much as possible. When guidance materials are used, they should be clearly labelled as non-mandatory and non-authoritative. Guidance has the potential to be misconstrued as mandatory requirements and/or to be misaligned with the standards themselves. Further, we believe that content should be developed for inclusion directly within standards as opposed to being incorporated by cross-reference to external standards or guidelines. Many issues can arise when cross-referenced materials are used that are not developed using the same conceptual framework, leading to confusing and sometimes conflicting requirements. As these external standards and guidelines change over time, this may lead to further misalignment."]
["Survey","Shell","Preparer (non-financial preparing a sustainability report)","United Kingdom","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I disagree","As indicated in our response to question 23, we believe that no new datapoints should be added to the ESRS by exception or otherwise, as this runs counter to the objectives of this simplification effort."]
["Survey","Shell","Preparer (non-financial preparing a sustainability report)","United Kingdom","32.","ESRS G1 DR G1-2 and G1-6: Payment practices The revision of ESRS G1 has led -among others - to the deletion of former paragraphs 14 and 33(a), addressing \"payment practices\" (within the context of management of relationship with suppliers). These datapoints have been replaced by the PAT provisions and an additional specification for SMEs in paragraph 33(b). However, this deletion may still reduce visibility on how undertakings engage with and support SMEs. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Is the current replacement/formulation sufficient to meet the objectives of the CSRD in respect to the protection of SME's?","I partially agree and partially disagree","We support the removal of the disclosure requirement for the description of a company's policy to prevent late payments, specifically to SMEs, and the datapoint on average time to pay an invoice. These disclosures are overly burdensome and provide limited insights as they are difficult to interpret in a decision-useful way, and the revision to rely on more principles-based general disclosure requirements for policies is appropriate. We question the relevance and practicality of the revised datapoint on standard payment terms. For large undertakings, standard payment terms may vary from country to country for commercial or regulatory reasons. We note that the UK has proposed new disclosure requirements on payment practices. We encourage EFRAG to consider the opportunities for interoperability."]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","EDF does not support the new guidance on gross versus net approach, for the following reasons: (1) the proposed rules are overly complex and introduce significant judgement; (2) they would impose burden on companies by changing the methodology, and (3) information on gross impact is key to understand the context of mitigation measures.  In particular, Annex C creates confusion by mixing reporting for the current and subsequent year, which is conceptually inconsistent. EDF therefore recommends deleting it. The ESRS should focus on a general principle: potential impacts shall be assessed before prevention or mitigation measures (i.e., expected effects of ongoing or future actions). The terms gross and net should be avoided, since they cause confusion, especially relative to logic of business risk assessment. A distinction could be made between: •\tActual impacts: to be assessed at the reporting date. In practice, whether impacts have occurred or not at the reporting date independently from the past mitigation actions.  •\tPotential impacts: to be assessed before considering prevention or mitigation actions. This reflects that sustainability actions are typically implemented over a multi-year horizon (e.g., carbon trajectory) and that some impacts may never be fully eliminated (e.g., health and safety)."]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I disagree","EDF proposes to apply Option 1 to E1 and to reduce the level of information required by E1-11 as EDF thinks it too granular and specific. As such, EDF would propose to match E1-11 to Option 1 only. At least certain datapoints should be deleted (or made voluntary), in particular: •\t§40(b): location (granular); •\t§40(c): adaptation actions (secondary); •\t§41(b): mitigation actions (secondary); •\t§41(e), revenue is not the financial metric which is relevant in utilities' sector (for example revenue is highly volatile with respect to commodity prices and does not enable to evaluate the performance of the activity). •\t§40(f): potential stranded assets (redundant with §40a); •\t§42: climate opportunities (entity-specific)."]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","22.ESRS2","Comments on deleted datapoints in ESRS 2","I partially agree and partially disagree","EFRAG has clearly engaged in a simplification effort, reflected in the reduced overall volume of the standards, improved readability, and a clearer distinction between may and shall provisions. Importantly, the key information required by investors to conduct ESG analyses remains available.  EDF notes that some alleviations listed in the French proposals for a simplification have not been considered by EFRAG - notably the deletion of some difficult DPs - which, cumulatively, could enable a more significant decrease in the reporting burden. Therefore EDF believes that further alleviation is feasible and necessary. In particular, every reduction of the number of datapoints which can be obtained for example by gathering datapoints in a single one is an important simplification for the future digital tagging."]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I partially agree and partially disagree","E3 - EDF do have water meters installed at each point. Moreover, EDF calculates its water consumption partly through estimations and modelling rather than by using the water balance approach. Consequently, these new datapoints contradict the principle of simplification  create greater complexity, and increase the audit costs.  G1 confirmed incidents: EDF is not in favor to change these datapoints on confirmed incidents from \"may\" to \"shall,\" as they are highly sensitive and of limited relevance.  Introducing mandatory reporting of confirmed incidents risks creating an unlevel playing field, as US companies may be exempted from comparable constraints.  Moreover, reporting confirmed incidents is not a reliable metric of anti-corruption policy effectiveness. A low number of incidents could reflect strong preventive measures, while a high number may indicate a trusted reporting system, particularly through whistleblowing channels. A simple numerical count or brief description of an incident's \"nature\" cannot capture its context, resolution, or remedial actions.   E4 : The notion of \"transition plan\" is not yet clearly defined. Companies explore the best ways to develop action plans on this highly complex subject, whether through national or international initiatives, but no official certification of such analyses and plans exists to date. \tThe plan should be made public by the company itself, not by a third party and the term \"publicly available\" should be clearly define. •\tA distinction should be made between a biodiversity action plan and a biodiversity transition plan."]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","EDF","Preparer (non-financial preparing a sustainability report)","France","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"Taxonomy consistency :  EDF calls for harmonisation between the Environmental Taxonomy and the ESRS. As the ESRS are simplified, the Taxonomy should also be streamlined to ensure coherence and complementary of sustainability information. EDF supports applying the materiality principle in the Taxonomy, as in the ESRS and IFRS, relying on qualitative and, where appropriate, quantitative criteria consistent with current practice. Given that DNSH criteria and minimum safeguards are often complex and inconsistently interpreted, EDF recommends aligning them with information on ESG PAT, metrics, and due diligence already reported under the ESRS. The Taxonomy's main value lies in ratio calculations, which users can interpret alongside ESRS disclosures.  Audit: the usefulness of a standard compared to guidelines The audit has posed significant challenges in the first year of ESRS implementation. While clarifications help, further issues will arise as audit practice develops and new concepts (e.g., fair presentation) are introduced. To ensure a consistent and comparable level of audit diligence across all EU jurisdictions, a binding audit standard applicable to all auditors is needed, which would provide a more robust framework than guidelines."]
["Survey","European Construction Industry Federation (FIEC)","Business association (other than association of financial institution)","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","With regard both to information on the gender pay gap and to other workforce-related information, it is important to maintain and/or introduce within the scope of the Standard the possibility for undertakings to provide disaggregated data as well as qualitative information capable of contextualising the quantitative data. This is also in order to take into account any specific characteristics of the undertaking's sector, thereby enabling users of the sustainability reporting to correctly read and interpret the information relating to the undertaking itself."]
["Survey","Technical University of Munich","Academia","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","From a machine-readability and data quality perspective lists of sites in the sustainability statements should be maintained. They are valuable, as they decrease the risk of Large Language Models (LLMs) to miss or misinterpret information, lists can be used as training data for LLMs and enable comparison between the list of sites and (narrative) data points."]
["Survey","Technical University of Munich","Academia","Germany","20.","ESRS E1: Disclosures on Anticipated Financial Effects The content of the disclosure requirements on Anticipated Financial Effects (formerly E1-9 now E1-11) has been significantly reduced. Several datapoints are still included, which are considered necessary for investors and lenders to be able to assess the undertaking’s exposure to transition and physical risk, including for lenders to be able to meet either supervisory expectations or sector specific disclosure requirements. This question focuses on paragraphs 40 (a) to (d), 41 (a) to (f) and 42 of ESRS E1 and aims at collecting feedback on the feasibility of the remaining datapoints. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering to this question, to avoid duplication of input, you will not be allowed to include comments on DR E1-11 or paragraphs 40, 41 and 42 of ESRS E1 in Part 3. Your comments on those provisions will only be provided here. Do you agree that the amended paragraph 40, 41 and 42 of ESRS E1 have been sufficiently simplified and that they strike the right balance between reporting effort and users’ needs?","I agree",null,null,null,""]
["Survey","Technical University of Munich","Academia","Germany","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I agree"]
["Survey","Ernst & Young","Auditor","United Kingdom","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree","We welcome the proposed amendments on the structure of sustainability statements, with some points of attention.   Allowing undertakings to include an executive summary and appendices improves the readability of sustainability statements and better reflect preparers' practices. The 'connected information' clarification enables undertakings to avoid fragmentation and duplication of information.  However, we ask EFRAG to: - Clarify whether the executive summary should provide a faithful representation of all material IROs (§4) or if it could follow a management approach. For example, may it include only those IROs currently monitored by management or should it include a summary of all material IROs that are relevant to stakeholders, including those that are not yet managed or embedded in strategy? - Specify that appendices should also meet the requirements for qualitative characteristics of information.  - Clarify that information disclosed in appendices should not be presented or interpreted as \"not material\" or \"less relevant\" than information disclosed in the main body of the sustainability statement (except for additional disclosures that do not relate to a topic identified as material as referred in §108), - Non-material Information covered by § 108 is more appropriately placed in appendices for clear identification. Such additional disclosures should also clearly be identified in the IRO-2 table.   Notwithstanding the general principle on connectivity in ESRS 1, we disagree with the removal of mandatory reconciliation of amounts between the sustainability statement and the financial statements, both for \"direct connectivity\" (same amounts in both statements) and \"indirect connectivity\" (aggregated amounts or parts of an amount). This change bears negative implications for users on overall connectivity, consistency and readability and it contradicts stakeholders' and supervisors' (notably ESMA) increasing attention to the integration and consistency of sustainability and financial reporting in recent years."]
["Survey","Ernst & Young","Auditor","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","Interoperability is essential for users and critical to reduce the reporting burden of reporting entities. We commend EFRAG's efforts to improve interoperability, but we are concerned that some revisions will introduce new differences. We strongly recommend that EFRAG works with the ISSB when finalising ESRS to further improve interoperability. We also stress the importance of updating the interoperability guidance.  Regarding point 1, please refer to Q.25.  Regarding point 2, we disagree with the proposed approach. We recommend leaving the choice open based on the consolidation approaches of the GHG Protocol, as required in most GHG related standards, including IFRS S2. Imposing a double reporting for companies that have historically had targets and communication based on operational control works against simplification and interoperability.  For points 3 and 4, please refer to Q.17 and 19 and comments in Part 3. While both ISSB standards and ESRS now include the relief related to \"undue cost or effort\", full alignment is not achieved due to differences in scope where this concept applies. EFRAG should work with the ISSB to assess the impact of these differences and explore ways to address it. The other ESRS reliefs which create new differences to be assessed with the IASB before finalizing ESRS. Any remaining difference should be identified in the interoperability guidance to clarify which reliefs should not be applied for dual compliance purposes.  The resilience-related disclosure now requires only qualitative information (§24). We recommend retaining the current wording in §48(f), aligned with IFRS, and leave the wording in E1-3 unchanged.   On point 8, although some wording differences remain (e.g. financed emissions), we do not see major hurdles (apart from those indicated in Part 3). The results are comparable and it is understood that EU legislation need to be reflected in ESRS."]
["Survey","Ernst & Young","Auditor","United Kingdom","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I partially agree and partially disagree","Biodiversity target setting practices are still emerging. We suggest EFRAG to provide some clarifications or examples in NMIG to support consistent reporting across undertakings, enhancing comparability of the disclosed information.   Better alignment with latest science-based frameworks, drawing where appropriate from TNFD and SBTN - which provide guidance for elaborating various nature-related targets and examples – would enhance relevance, comparability, comprehensibility."]
["Survey","Ernst & Young","Auditor","United Kingdom","33.E_3.","ESRS E3:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","Overall, we welcome the simplifications. As detailed in our comments below in Part 3, we ask some clarification on recycled or reused water, and water storage calculation methodology, to reflect the complexity of water flows and support consistent reporting for entities.   Finally, considering that E1 and E2-E5 comprehend all environmental matrices, consistency should be fostered on reporting boundaries/approach – e.g. operational/financial control approach –, enhancing reporting coherency towards stakeholders."]
["Survey","Ernst & Young","Auditor","United Kingdom","34.","Any other comments Please provide here any other comments on the 12 EDs or on the Glossary",null,"We suggest EFRAG to clarify in the Basis for Conclusions which revisions in the Exposure Drafts represent actual changes (such as new reliefs) and which revisions represent clarifications of ESRS Set 1 requirements which could therefore be reasonably considered by companies and auditors in the FY2025 reports.   In addition, we highlight the need to ensure consistency between the ESRS and other EU regulations so that preparers and users benefit from a clear framework, homogeneous and harmonized with other existing regulatory requirements. It is of the utmost importance for financial institutions, for which interaction and consistency with reporting requirements should be reached, including with EBA guidelines on ESG risks and transition plans as well as standards on Pillar 3 disclosures is essential.  We also strongly recommend to retain in ESRS 1 the principle included in ESRS 1 Set 1 §115, according to which disclosures pursuant to Article 8 of the Taxonomy Regulation \"are not subject to the provisions of ESRS\"."]
["Survey","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I agree","We fully support the changes introduced as regards the distinction between mandatory from voluntary datapoints, as it was flagged as one of the main sources of confusion during the preparation of the sustainability statements, also presenting challenges with auditors.  However, further simplification and precision are needed to improve usability and avoid confusion, particularly with auditors.  -\tUnclear and contradictory terminology should be eliminated. For instance, terms such as \"shall consider\" create ambiguity: \"shall\" implies mandatory action, while \"consider\" suggests discretion. This phrasing leaves room for interpretation and could result in inconsistent application or auditor disputes. -\tApplication requirements (ARs) that use \"may\" should be removed, as \"may\" implies voluntary action, which contradicts the stated objective of eliminating voluntary disclosures. Clear, mandatory language is essential to ensure consistency and enforceability across undertakings. -\tIn addition, the term \"significant\" is unclear. ESRS should explain that companies should assess significance in their own context, so that disclosures remain relevant and material. -\tTo make the ESRS even simpler, EFRAG could move definitions to the Annex II glossary, place illustrative examples in the NMIG, include presentation guidance directly in the datapoints, and remove optional ARs"]
["Survey","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland","22.ESRS2","Comments on deleted datapoints in ESRS 2","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland","22.E5.","Comments on deleted datapoints in ESRS E5","I agree","We support the deletion of mandatory datapoints as proposed by EFRAG as it will reduce the administrative burden on reporting undertakings and will enhance the effectiveness of sustainability reporting under the ESRS."]
["Survey","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland","27.","ESRS S1: New threshold for reporting metrics disaggregated at country level Amended ESRS S1 changes the threshold for the requirement to disaggregate the metrics for Characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1). Refer also to Basis for Conclusions (BfC) Chapter 8. Instead of being defined based on at least 50 employees by head count representing at least 10% of the total number of employees, the requirement is now to disaggregate the metrics for the top 10 largest countries by employee headcount, to the extent that there are more than 50 employees in those countries. A minority of EFRAG SRB members noted that this change could trigger, in some cases, an increase in the number of countries to report on for these two disclosures, and so an increased burden to prepare the information. The majority of EFRAG SRB members supported the change because the current requirement has led to limited information available by country. In addition, the information is usually easily accessible, so the burden to prepare the information per the new requirement is estimated to be limited. If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, to avoid duplication of input, you will not be allowed to include comments on DR ESRS S1-5 and ESRS S1-7 in Part 3. Your comments on those provisions will only be provided here. Do you agree with the change to the threshold for country-by-country disclosure for the DRs ESRS S1-5 and ESRS S1-7? ","I disagree","We are concerned that the revised workforce disclosures introduce a level of detail that is not necessarily relevant or decision-useful, particularly for multinational companies. The requirement to disclose employee numbers per country with more than 50 employees may add little value, as in practice these employees may be concentrated in a single region (e.g., Europe) without enhancing the reader's understanding of global workforce distribution. A more representative and meaningful approach would be to return to the previous version of the disclosure, which required companies to report on countries where there are more than 50 employees representing at least 10% of the total workforce. This ensures focus on material geographies while avoiding unnecessary granularity.  We also recommend removing the requirement to disaggregate employees by contract type (permanent, temporary, non-guaranteed). While well-intentioned, this requirement offers limited value to users and creates disproportionate complexity for preparers. Contract categories are defined differently across jurisdictions, leading to inconsistencies and undermining comparability. Moreover, workforce composition often fluctuates throughout the year, particularly in industries with seasonal demand or project-based work, which reduces the reliability of such disclosures."]
["Survey","Finnish Energy","Business association (other than association of financial institution)","Finland","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I disagree","We consider the proposed guidelines overly complex and detailed, which risks making the materiality assessment unnecessarily burdensome. A more general, principle-based approach would be more appropriate and effective.  We recommend that impacts (and risks) be reported before mitigation or corrective actions, with a subsequent explanation of how these will be addressed. This would provide greater clarity and ensure alignment with established enterprise risk management practices.  Moreover, clearer guidance is needed to distinguish between actual and potential impacts, as the current proposal does not sufficiently clarify this important distinction."]
["Survey","Finnish Energy","Business association (other than association of financial institution)","Finland","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We welcome the proposed burden reliefs. It is important that the amendments emphasize prioritisation and materiality, which will help focus reporting efforts where they are most relevant. We recognise that some of the reliefs may create challenges for data collection, especially for companies within the mandatory reporting scope, but consider these manageable through contractual and practical arrangements. We note, however, that several definitions, such as \"undue cost or effort\" or \"lack of data quality\" remain open to interpretation and should be clarified to ensure consistent application across companies."]
["Survey","Finnish Energy","Business association (other than association of financial institution)","Finland","25.","Emphasis on ESRS being a “fair presentation” reporting framework The Amendments clarify that ESRS is a fair presentation reporting framework, as it is for IFRS S1 and S2, with the expectation that this will support a more effective functioning of the materiality filter and reduce the check list mentality associated to the adoption of a compliance approach. Adopting fair presentation is expected to support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material. The majority of the EFRAG SRB members consider that ESRS was already conceived as a fair presentation framework and interpret the CSRD as requiring it. A minority of the EFRAG SRB members think that the CSRD does not require fair presentation. They think that adopting fair presentation is not a simplification, due to the difficulty of exercising judgement of what is needed to fulfil the requirement, in particular for impact materiality where there are less established reporting practice. They think that the Amendments may result in increased legal risks and audit costs. Do you agree that explicitly requiring to adopt fair presentation in preparing ESRS sustainability statements will support a more effective functioning of the materiality filter, therefore enabling more relevant reporting and reducing the risk of excessive reported information?","I agree","We support the fair-presentation concept. It is important to understand, as stated in the question, that confirming the fair presentation concept should reduce the check list mentality associated to the adoption of a compliance approach, and support a reduction in the unnecessary reported information and of the documentation needed to show that omitted datapoints are not material."]
["Survey","Finnish Energy","Business association (other than association of financial institution)","Finland","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome the changes introduced in ESRS E4. The removal of topic-specific Disclosure Requirements (DRs) helps to streamline the reporting process and reduces unnecessary repetition and overlaps within the standard. This simplification makes it easier for preparers to navigate the requirements and ensures that the focus remains on material information.  In addition, the consolidation of site-level information under E4 SMB-3 with other site-related data in section E4-5 is a positive development. This integration not only reduces duplication but also provides a more coherent and structured presentation of site-level disclosures. Companies will benefit from a clearer and more consolidated framework for reporting site information, which supports consistency and comparability across the reporting entity."]
["Survey","Finnish Energy","Business association (other than association of financial institution)","Finland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree","We welcome the explicit reference to ESRS 2 within ESRS S2, as it reinforces the connection between general disclosure requirements and topical standards, contributing to a more coherent reporting framework.  We also note the improved clarity regarding vulnerable stakeholders. This enhancement helps companies better identify and disclose impacts on stakeholders who may be most affected by their activities, supporting more targeted and meaningful reporting."]
["Survey","Nordic Sustainability","Consultant (including software vendor)","Denmark","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I partially agree and partially disagree"]
["Survey","The Investor Relations Society","Other - please specify (required)","United Kingdom","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I partially agree and partially disagree","The amendments improve interoperability/alignment with IFRS S1 and S2 by aligning language, adopting the financial control approach for GHG boundaries, incorporating several IFRS reliefs and removing a lot of duplication. However, as EFRAG acknowledges, reliefs extending beyond IFRS provisions create new differences, which means some interoperability gaps remain. We also note that the text has become more technical, which may create a more lengthy/expensive process for preparers."]
["Survey","Bayer","Preparer (non-financial preparing a sustainability report)","Germany","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","We agree that the DMA should remain a principles-led process, enabling contextual judgment and supporting a meaningful connection between an undertaking's strategy and its sustainability reporting. This is essential to maintaining the integrity, usability, and comparability of disclosures. Companies should not be required to disclose detailed methodological descriptions in their CSRD reports, nor should they be asked to provide unnecessary scoring details for topics that are clearly either material or immaterial. The process must remain company-specific and principles-based, avoiding excessive documentation and supporting meaningful, decision-useful disclosures. While expanding the DMA into sector- or industry-specific instructions may appear helpful, it risks undermining its core purpose: empowering undertakings to apply professional judgment within their unique context. The ESRS framework rightly positions materiality as the primary filter for disclosures, promoting a top-down, strategy-driven approach rather than a compliance-oriented checklist. Efforts to pre-empt DMA outcomes—by implying sectoral relevance, suggesting indicative material topics, or embedding assumptions—risk reintroducing the complexity and rigidity that the framework aims to eliminate. Supportive resources, such as the Non-Mandatory Illustrative Guidance (NMIG) can be valuable tools for preparers. However, it is crucial that such materials remain clearly non-authoritative and distinct from the core standards, therefore they should be eliminated from the standards to avoid implicit obligations under a non-mandatory status. Companies should only carry out a full DMA periodically or when there are significant changes in their strategy or business model.  The application of the \"fair presentation\" principle continues to pose challenges for companies on how it can be implemented in practice. Should the principle be retained in EFRAG's final technical advice, ultimate responsibility for the report — and for the assessment of fair presentation — rests with the reporting entity's management."]
["Survey","Bayer","Preparer (non-financial preparing a sustainability report)","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I disagree with both Options","These disclosures are neither feasible nor reliable in reflecting a company's financial situation and pose significant risks of legal proceedings if included in financial statements. Notably, there is no requirement in financial reporting regarding \"anticipated financial effects\" for non-ESG topics. If this obligation is retained, companies should at minimum be allowed to provide qualitative information only, and benefit from a Level 1 relief to protect sensitive business information, including trade secrets."]
["Survey","Bayer","Preparer (non-financial preparing a sustainability report)","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I partially agree and partially disagree","The definition and calculation of living wage benchmarks can vary widely from country to country, depending on local institutions, data availability, and socio-economic conditions. Without a standardized framework or clear disclosure requirements on which tier of the hierarchy is used, companies may face challenges in ensuring comparability, transparency, and internal alignment. This could lead to fragmented reporting, misinterpretation of wage adequacy, and reputational risks if stakeholders perceive wage disclosures as insufficient or misleading. The changes proposed seem to partially address these concerns as they give more clarity and flexibility to reporting undertakings."]
["Survey","BETTER FINANCE","NGO","Belgium","11.","Clarifications and simplification of the Double Materiality Assessment (DMA) (ESRS 1 Chapter 3) and materiality of information as the basis for sustainability reportingRationale for the changes The Amendments have clarified the requirements in ESRS 1 Chapter 3 about materiality of information and simplified the DMA process. They are described in Lever 1 of simplification in the Basis for Conclusions (see BfC Chapter 4). Link here to access the Log of Amendments, ESRS 1, Chapter 3 if you would like to review the detailed Amendments and their rationale. The Explanatory Memorandum (EM) which accompanies the EC Omnibus proposals (page 5) identified the following objective for this lever: “[the simplification] will provide clearer instructions on how to apply the materiality principle, to ensure that undertakings only report material information and to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process”.Description of the changes To meet this objective, EFRAG has introduced the following changes which aim to strike a balance between simplification and the necessary robustness of the Double Materiality Assessment (DMA): A new section presenting practical considerations for the DMA has been drafted, including the option of implementing either a bottom-up or top-down approach (Chapter 3.6 of ESRS 1) \tMore prominence has been given to materiality of information as a general filter and all the requirements are subject to it. \tThe relationship of impacts, risks and opportunities, and topics to be reported has been clarified (ESRS 1, paragraph 2 and 22) \tIt has been explicitly allowed to include information about non-material topics (ESRS 1, paragraph 108) if they are presented in a way that avoids obscuring material information \tEmphasis is put on ESRS being a fair presentation framework, to reinforce the effectiveness of the materiality principle and avoid excessive documentation effort due to a compliance and checklist approach to the list of datapoints (DP); an explicit statement of compliance with ESRS is included in (ESRS 1, Chapter 2) \tTo avoid excessive detail in reported information, it has been clarified that all the disclosures can be produced either at topical level or at impacts, risks and opportunities (IRO) level, depending on the nature of the IROs and on how they are managed \tThe list of topics in AR 16 (now Appendix A) has been streamlined by eliminating the most detailed sub-sub-topic level and has now an illustrative only and non-mandatory status. \tMore emphasis has been put on the aggregation and disaggregation criteria for reporting information at the right level. Explanations have been provided with respect to the consideration of sites for the DMA and reported information, so as to avoid long lists of sites being included in the sustainability statement.  Please do not comment here in “Gross versus Net” as it is covered by the next question.Question If you intend to provide feedback also on Part 3 of this questionnaire (at level of DR or paragraph), please note that by answering this question, you will not be allowed to include comments on Chapter 3 of ESRS 1 in Part 3, to avoid duplication of input. Your comments on Chapter 3 can only be provided here. Do you agree that the proposed amendments have sufficiently simplified the DMA process, reinforced the information materiality filter and have succeeded in striking an acceptable balance between simplification and robustness of the DMA? Do you agree that the wording of Chapter 3 of ESRS 1 is sufficiently simplified?","I partially agree and partially disagree","EFRAG's amendments to the Double Materiality Assessment (DMA) aim to simplify reporting, but for end-users such as individual investors the changes are only partially acceptable. The option to apply a top-down or bottom-up DMA (Ch. 3.6) recognises different practices, but without clear guardrails on thresholds and evidence, it risks divergence: two firms could reach opposite conclusions on the same issue. A short method note explaining approach, thresholds, and stakeholder inputs would strengthen comparability. Applying materiality as a filter to all requirements reduces box-ticking, but the lack of a baseline of always-on disclosures (governance roles, pay links, climate transition plan status etc.) important investor-relevant data may disappear. The burden shifts to users to detect omissions. Clarifying the link between IROs and topics (ESRS 1, paragraph 2 and 22) improves logic, but without a mapping table of IROs to reported or omitted DRs, companies can still over-aggregate or selectively scope out issues, creating blind spots. Emphasising fair presentation and explicit compliance moves beyond checklists, but increases judgement, legal risk, and audit costs. Consistency could be improved by requiring a short, standardised assertion on exclusions and estimation reliance. Permitting disclosure at topic or IRO level cuts duplication, but mixed levels break data pipelines used by investors and regulators. Tabular anchors for key datapoints are needed to keep information extractable. Finally, streamlining AR 16 into a non-mandatory appendix and loosening site reporting declutter reports, but reduce signposts and can hide local outliers. A coverage checklist and \"outlier flag\" requirement would preserve comparability. In sum, while readability improves, the changes risk widening discretion and weakening transparency."]
["Survey","BETTER FINANCE","NGO","Belgium","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","Option 1 preserves the expectation of quantitative disclosure while permitting omission in defined, decision-useful circumstances. That approach is substantially aligned with the IFRS relief and therefore supports global comparability, while making two clarifications that matter in practice: companies may use the relief where there is no reasonable and supportable information from business plans to estimate long-term effects, and they may not claim lack of internal skills or resources as a reason to omit figures. For end-users, this balances feasibility with accountability. Choosing Option 1 should come with safeguards so the relief does not become a soft escape hatch. First, issuers that omit quantitative estimates should provide a concise method note explaining the nature of the IRO, why separate measurement is not possible or why uncertainty renders figures not useful, and which business plan inputs were missing; this can be brief but must be specific. Second, when estimates are possible, ranges should be permitted and encouraged, with clear statements of key assumptions and drivers, consistent with the interoperability goal with IFRS S1/S2. Third, where numbers are omitted, companies should disclose the scope of activities affected and a time-bound plan to reach quantification, with year-on-year progress so users can track when the relief is phased out. Finally, because DR E1-11 remains a critical indicator of exposure to transition and physical risk even after simplification, Option 1's conditions should not be weakened further by other reliefs that already limit forward-looking visibility (for example, the separate constraint that limits \"investments and plans\" disclosure to items already announced)."]
["Survey","BETTER FINANCE","NGO","Belgium","30.","ESRS E4 DR E4-4: Application requirement to guide undertakings in setting biodiversity- and ecosystems-related targets As part of the simplification process, E4-4 (targets) disclosure specifications and application requirements have been mostly removed. In this context, methodological guidance for companies to what biodiversity and ecosystems-related targets can cover would be helpful.  ESRS SET 1, E4 AR 26) outlines aspects that targets can address, including in relation to the size of areas protected or restored, the recreation of natural surfaces or the number of company sites whose ecological integrity has been approved. While this AR could be kept in the revised ESRS E4, some stakeholders highlighted that it could be further reviewed to better reflect latest trends in the evolving methodological landscape related to biodiversity and a stronger alignment with relevant content from science-based frameworks such as SBTN. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you agree with the review of AR 26 in Amended ESRS E4?","I agree","Reviewing AR 26 is the right move: after most of E4-4's specifications were stripped out, investors lost practical signposts for what a credible biodiversity target should look like. Refreshing AR 26 to reflect the fast-moving methodological landscape, especially the Science Based Targets for Nature (SBTN), would reduce ambiguity for preparers and help retail investors recognise when targets are decision-useful rather than marketing claims. The review of AR 26 should consider adding investor-oriented guardrails, like site-level triggers: if a material site sits in or near a biodiversity-sensitive area, disclose site-specific targets or explain exceptions and require progress vs milestones."]
["Survey","BETTER FINANCE","NGO","Belgium","31.","ESRS S1 DR15: Gender pay gap Some of the feedback obtained during the public outreach on the Remuneration metrics (ESRS S1-15), which are derived from the SFDR PAI, was to revisit the gender pay gap ratios and consider replacing it by the adjusted gender pay by employee category or, in some cases, by country. The gender pay gap metric in set 1 is aligned with the Pay Transparency Directive, (EU) 2023/970, where the unadjusted ratio is required as a global percentage and the adjusted gender pay gap by employee category is a voluntary (“may”) datapoint. The voluntary datapoint of adjusted gender pay gap by employee ratio has not been included in Amended ESRS S1, following careful analysis and consideration of the EFRAG SRB where the pros and cons of changing the basis for gender pay gap were weighted. The conclusion reached was to maintain the global unadjusted pay gap and delete the adjusted gender pay gap by employee ratio that  is a voluntary datapoint in set 1. The deletion of voluntary datapoints obey to the general approach in the revised architecture. If the respondents intend to comment on the respective paragraphs of Section 3, they will not be permitted to do so. Do you  agree with the deletion of the voluntary datapoint on adjusted gender pay gap?","I disagree","A company can improve the unadjusted gap by altering workforce composition without addressing equal pay for equal work. Deleting the adjusted metric leaves end-users with a single ratio that is highly sensitive to changes in headcount mix and therefore prone to misinterpretation. It also weakens stewardship leverage, because investors cannot test whether management's \"equal pay\" claims are borne out by controlled analysis. Maintaining only the unadjusted figure also undermines comparability across countries and categories. Investors need to see whether gaps persist in key job families and major jurisdictions, because litigation, turnover, and reputational risks arise locally and can be financially material. Without an adjusted, category-or country-level view, issuers with identical global gaps can mask very different underlying realities, frustrating proxy voting, engagement, and SFDR-linked screening.   Concerns about burden and consistency can be addressed without deletion. ESRS S1 could require a short method note (definition of \"adjusted,\" variables controlled for, statistical model, coverage, handling of part-time/temporary staff) and a lean disclosure set: adjusted gap for major employee categories and the top countries by headcount, alongside the global unadjusted figure, pay-quartile distribution, and a remediation plan where gaps exceed a threshold. A phased implementation and alignment with Pay Transparency Directive methodologies would limit cost while improving reliability and  digital tagging would preserve extractability."]
["Survey","BETTER FINANCE","NGO","Belgium","33.E_4.","ESRS E4:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","University Pension Plan","Other - please specify (required)","Canada","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","UPP supports the proposed structural changes as they will likely lead to more concise and comparable disclosures that would be easier to use for investors.   However, the deletion of \"may disclose\" datapoints is concerning, and we are opposing this proposal. These datapoints often provided helpful examples of relevant disclosures, especially in areas where reporting practices are still evolving (e.g., biodiversity, social metrics). Moving them entirely into Non-mandatory Illustrative Guidance ('NMIG') creates additional complexity and does not support transparency for investors."]
["Survey","University Pension Plan","Other - please specify (required)","Canada","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We acknowledge that the introduction of horizontal reliefs (such as \"undue cost or effort\" and \"lack of data quality\") provides flexibility and can reduce the overall burden for preparers.   However, we are concerned that the scope and structure of some reliefs risk undermining consistency, comparability and interoperability on a global scale for companies operating in different jurisdictions: - Reliefs that allow disclosure of only a subset of operations or activities (e.g., joint operations or newly acquired subsidiaries) may lead to a misalignment between companies' financial statements and their reported sustainability risks. This weakens the principle of connectivity between financial and sustainability reporting  - During transition periods, limiting disclosures to principal segments or subsets of the reporting entity reduces investors' ability to understand company-wide exposures, and risks inconsistent comparability between EU companies and those applying ISSB Standards in other jurisdictions  - The lack of explicit time-bound requirements for improving data quality or coverage when reliefs are applied may incentivize companies to rely on reliefs indefinitely, undermining the goal of robust reporting.  We recommend narrowing or removing reliefs that alter the reporting boundary (e.g., acquisitions/disposals, joint operations) to preserve alignment with ISSB and ensure consistency with consolidated financial statements to equip investors with comparable decision-useful and up to date information."]
["Survey","University Pension Plan","Other - please specify (required)","Canada","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","UPP does not support this proposal. The proposed methodology would generate inaccuracies in adequate wages outside of the EU. Further it places an unreasonable burden on individual companies to assess whether legal minimum wages or living wage estimates align with ILO principles. The resulting data inconsistency harm comparability of data for investors."]
["Survey","BDO Poland","Auditor","Poland","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree","Any simplification in understanding the standards and applying them in practice will be a positive step."]
["Survey","BDO Poland","Auditor","Poland","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","BDO Poland","Auditor","Poland","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I agree","If we are indeed provided with a clear reference to which report or guidelines to follow regarding adequate pay, it will definitely be a positive step toward transparency. Currently, the lack of such data leads companies to report that all employees receive at least the legal minimum wage in the country where they operate. However, this tells us nothing about the actual adequacy of the remuneration."]
["Survey","BDO Poland","Auditor","Poland","33.E_2.","ESRS E2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","BDO Poland","Auditor","Poland","33.S_2.","ESRS S2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","University of Córdoba","Academia","Spain","13.","Improved readability, conciseness and connectivity of ESRS Sustainability StatementsRationale for the changes Starting with the input gathered from the first-time adopters, EFRAG has introduced several changes to support the production of more readable and concise sustainability statements, that are better connected with corporate reporting as a whole. This corresponds to Lever 2 of simplification in the Basis for Conclusions (BfC) (Chapter 4).Description of the changes EFRAG has clarified the flexibility that preparers have in preparing their statements. The Amendments describe the possibility of including an 'executive summary' at the beginning of the sustainability statement and have put greater emphasis on the use of appendices to separate more detailed information from key messages. The amendments have also clarified the concept of ‘connected information’, discouraging fragmentation and/or repetition of information (ESRS 1, Chapter 8).Question Do you agree that these proposed Amendments, when combined with the other changes in the Amended ESRS, provide an appropriate level of flexibility to support more relevant and concise reporting, as well as to promote better connectivity with corporate reporting as a whole?","I agree"]
["Survey","University of Córdoba","Academia","Spain","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I disagree","C, M, N: Disagree The \"undue cost or effort\" principle is aligned with the goal of administrative simplification. However, the articulation of this \"relief\" in paragraph 89 ESRS1 is so imprecise that it may turn this set of standards into dead letter.   The \"undue cost or effort\" principle risks transforming Directive (EU) 2022/2464 into a voluntary guideline."]
["Survey","University of Córdoba","Academia","Spain","26.","Exception for Financial Institutions' Absolute climate reduction Targets One of the implementation challenges noted by financial institutions relates to the requirement in ESRS E1 paragraph 26(a). This requires, when the undertaking has adopted GHG emissions intensity targets in conjunction with AR12 (“when only setting intensity targets”), to disclose also the associated absolute values” (refer also to Basis for Conclusions (BfC) Chapter 8). EFRAG SRB and SR TEG discussed whether an exception would be needed for insurance, banking and asset management sectors, but they decided that it would be appropriate to receive specific feedback before concluding. Those that support the exception argue that this information is not useful. They think that while for fossil fuel sectors gradual de-commissioning is foreseen, emphasising the role of absolute targets for lenders and investors in all sectors would provide the wrong incentive, as high-emission sectors are those in need of transition financing. They also consider that estimating the absolute targets would require multiple assumptions (such as about the composition of the portfolios, the production capacity, the market shares and the level of emission intensity), making results unreliable and thus not leading to meaningful disclosures. Those who oppose this exception note that complex estimates are common to all sectors. They also note also that both the information types of intensity and absolute targets are needed for a proper understanding of the undertaking’s progress on climate and banks are no exception in this case. Intensity targets, while capturing efficiency, may mask rising emission levels. Absolute targets capture the total impact but fail to take into account the effect of business growth. They finally note that an exception only for financial institutions would result in an unlevel playing position for the other sectors.    ","I disagree that financial institutions should be exempted from disclosing climate absolute GHG emission values targets when they have only set intensity targets","Complex estimates are common to all sectors. The financial sector has a disproportionate effect on climate change. Absolute targets are essential for assessing progress on climate change, and banks are no exception in this regard."]
["Survey","University of Córdoba","Academia","Spain","33.ESRS2.","ESRS 2:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","University of Córdoba","Academia","Spain","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Environmental Defense Fund","NGO","United States","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","Further language simplification on definitions and explanations should be considered."]
["Survey","Environmental Defense Fund","NGO","United States","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I agree"]
["Survey","Environmental Defense Fund","NGO","United States","23.","Six datapoints exceptionally moved from “may” to “shall” In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, “may disclose” datapoints have not been transformed into mandatory ones (subject to materiality). In the context of the comprehensive revision of some of the DRs, to provide for more focused and relevant information, 6 datapoints have been moved from “may” to “shall” subject to materiality. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter Appendix 3. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Environmental Defense Fund","NGO","United States","33.E_5.","ESRS E5:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree"]
["Survey","Environmental Defense Fund","NGO","United States","33.G_1.","ESRS G1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I agree"]
["Survey","Business & Human Rights Resource Centre","NGO","Germany","19.","Relief for anticipated financial effectsRationale for the changes Preparers’ feedback to the public call for input indicated that disclosing quantitative information for financial effects is particularly challenging. This includes issues of lack of mature methodologies and being commercially sensitive (refer to Basis for Conclusions (BfC) Chapter 7). Suggested solutions included the IFRS corresponding relief (IFRS S1 paragraph 37), the deletion of the requirement to report quantitative information, or to report them only on a voluntary basis. The EFRAG SRB is specifically seeking input that would support the determination of the most appropriate relief.Description of the changes The Amended ESRS currently includes two possible options, which would apply to all topics, including climate (DR E1-11): a) Option 1 requires an undertaking to disclose both qualitative and quantitative information but allows omission of quantitative information under certain conditions. Option 1 is substantially aligned with the IFRS relief, despite the fact that it includes some differences compared to it: under Option 1, as in the IFRS relief, the undertaking need not provide quantitative information when it is not able to measure separately the financial effect of a specific topic (or IRO) or when the level of uncertainty is so high that the resulting information would not be useful. Differently from the IFRS relief, Option 1 specifies that the undertaking may use the relief when there is no reasonable and supportable information derived from its business plans to be used as input in the calculation of anticipated long-term financial effects. Different from the IFRS relief, the undertaking cannot omit quantitative information when it does not have the skills, capabilities or resources to provide that quantitative information, as this part of the relief was considered not compatible with the entities that are expected to be in scope of the Amended ESRS. b) Option 2 limits the requirement to qualitative information only, and leaves companies to choose to report quantitative information on a voluntary basis, without having to meet any conditions.  This option is not aligned with the treatment in IFRS S1 and S2. Some of the EFRAG SRB members noted that Option 2 would result in undue loss of information important for investors and would fail to provide the correct incentive to build more mature methodologies and reporting practices. Other members, on the contrary, supported the inclusion of Option 2.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 23 of ESRS 2 in Part 3 to avoid duplication of input. Your comments on that paragraph can only be provided here. Please select from the alternatives below the one that represents your view:","I agree with Option 1","While option 1 is still excessive in terms of a relief, option 2 is wholly unacceptable as such information is key to the EU's sustainable finance framework. There is no justification to go beyond the IFRS relief."]
["Survey","Business & Human Rights Resource Centre","NGO","Germany","28.","ESRS S1: Calculation approach to adequate wages outside the European Union (EU) The Amended ESRS S1 reflects an amended methodology for the calculation of non-EU adequate wages set out in the Application Requirements (ESRS S1 AR 22). This change draws on language from different parts of the agreement on the issue of wage policies, including living wages, adopted by the ILO Governing Body in 2024, after the ESRS Delegated Act was adopted. A minority of EFRAG SRB members flagged three interrelated concerns: (1) the reference to wage-setting principles risks disclosures of minimum wages that fall well-below an adequate wage standard, (2) the hierarchy requires companies to only assess relevant living wage data sets as a last resort, and (3) the DR/AR does not require companies to disclose which prong of the methodology is used, which leads to lack of comparability. In consideration of the complexity of this issue, EFRAG is running a targeted field test and is interested in involving a diversified sample of companies. This entails participating in dedicated working sessions with EFRAG Secretariat where the company is expected to present how the revised methodology is feasible and relevant in practice (refer to the non-EU hierarchy described in ESRS S1 paragraph AR 22 (b) i) to iii) to ensure transparency and comparability on this issue. A dedicated questionnaire will be sent directly to the companies participating in the test to allow for their preparation. The working sessions will take place between 8 and 26 September. To confirm your interest in participating to the field test on Adequate Wage please send an email to fieldtestadeqwages@efrag.org by August 18, 2025. Do you agree with the proposed change to the methodology for the calculation of non-EU adequate wages in ESRS S1?","I disagree","The new methodology is problematic and discriminatory as it risks conflating living wages, or in the EU terminology 'adequate' wages, with minimum wages, especially for employees outside the EU. For EU employees, companies in their reporting must compare actual wages against wage levels established through collective bargaining or an 'adequate' minimum wage set in line with the EU Directive on Adequate Minimum Wages. Regarding their non-EU employees, however, there is an option for companies to measure actual wages against statutory minimum wages set in line with the ILO wage-setting principles, a process standard that, unlike the aforementioned EU directive and the ILO principles on estimating living wages, is not relevant in itself to the estimation of living wages.  A living wage is widely recognised as a human right and describes the minimum income needed for workers to meet the most basic needs – food, housing, transport, clothing, healthcare, etc. – for themselves and their families. However, statutory minimum wages especially in low-income countries are often way below the living wage. According to WageIndicator (https://wageindicator.org/salary/minimum-wage/minimum-wages-higher-than-living-wages-by-country-and-by-region), only 29 of 178 countries tracked have a statutory minimum wage above the living wage level, mostly in Western Europe. The final reporting methodology must ensure all wages, EU and non-EU, are compared against a living/adequate wage in line with the EU minimum wage directive and ILO principles on estimating living wages. As government implementation, even in instances where it has strong legislation and standards, may be poor and/or delayed, documented evidence of independent trade unions' approval of a given wage level in robust social dialogue and collective bargaining is key to ensure reliability of metrics. Companies can and must engage in this and foster an enabling environment for social dialogue and collective bargaining."]
["Survey","Tanso Technologies GmbH","Consultant (including software vendor)","Germany","16.","All:16. Usefulness and status of “Non-Mandatory Illustrative Guidance” (NMIG) As a result of the simplification process, part of the mandatory content in the 2023 Delegated Act has been moved to “Non-Mandatory Illustrative Guidance” (NMIG). NMIG does not address all the existing implementation questions on each standard. It simply gathers the content that: a) was in the Delegated Act b) is now deleted; and c) contributes to the overall datapoints reduction. It contains ‘how to report’ guidelines (methodology) and examples of possible items to cover when disclosing in accordance with a mandatory datapoint, mainly for narrative PAT disclosures. Its content should not be understood as a list of items of information requiring justification when not reported, consistent with the fact that the previous datapoints are deleted. The legal status of the NMIG will be considered by the European Commission (EC) in due course.  However, EFRAG recommends that the EC not include this content in the Delegated Act. On the one hand, NMIG contains helpful support material that may reduce the implementation questions. On the other hand, it could trigger additional efforts of analysis and/or have an ambiguous role as possible additional disclosure with entity-specific relevance if issued within the Delegated Act.   You are invited to provide your comments on the purpose of NMIG, if any. You can access the NMIG at this link. Please select the NMIG you would like to comment on from the list below:","ESRS1; ESRS2; E1; E2; E3; E4; E5; S1; S2; S3; S4; G1","Comparability of disclosures remains a core purpose of the CSRD. Although we support the practical clarity and pragmatism introduced in the illustrative guidance, it remains to be seen how it will be adopted and used by preparers. We see the benefit of the NMIG, if regularly updated with examples, as a not legally binding guidance and harmonization instrument.   To additionally enable (automated) comparability between preparers, we urge EFRAG to keep datapoint IDs and tagging for the voluntary disclosures in the NMIG."]
["Survey","Tanso Technologies GmbH","Consultant (including software vendor)","Germany","24.","Four new mandatory datapoints (exception) In accordance with the simplification mandate received, EFRAG has adopted a general rule of not increasing the reporting obligations. Accordingly, no new “shall” datapoints have been added. In the context of the comprehensive revision of some of the DRs, to promote more focused and relevant information, 4 datapoints have been added. These exceptions are in the opinion of EFRAG justified. It is important to note that they do not add new obligations, as they refer to an already existing disclosure objective, but they make explicit a separate element of required information. In consideration of their very low number when compared to the overall datapoint reduction, they are not considered to jeopardise the achieved substantial simplification. On the contrary, their change of status improves the clarity of the reporting requirements. More details on these datapoints can be found in the Basis for Conclusions (BfC) Chapter 6. Do you agree that these exceptions to the general rule are appropriate and justified?","I agree"]
["Survey","Tanso Technologies GmbH","Consultant (including software vendor)","Germany","33.ESRS1.","ESRS 1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","E1 - Overall datapoint reductions are good. However, some of the datapoints still seem to be hidden in the ARs. We additionally urge to keep the revenue emission intensity as a key comparative indicator, as well as encouraging the disclosures on investments in climate mitigation, adaptation, transition opportunities."]
["Survey","Opportunity at Work","NGO","United States","14.","Restructuring of the architecture and interaction between ESRS 2 and Topical Standards Rationale for the changes The Amendments have restructured the architecture of ESRS, focusing on the interaction of ESRS 2 and topical standards. They have also modified the standard-setting approach for policies, actions and targets (PAT) to adopt a more principles-based and less prescriptive approach. These Amendments are described as Lever 3 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes, which aim to strike an appropriate balance between (a) prescriptiveness of the requirements and preparation effort and (b) the users’ need for relevant, faithful and comparable information: Minimum Disclosure Requirements in ESRS 2 (renamed “General Disclosure Requirements”) have been simplified but retained as ‘shall’ disclose. \tA drastic reduction of ‘shall’ datapoints PAT has been achieved, sometimes reformulating them as Application Requirements (‘ARs’) to support more consistent application. \tTopical specifications to GOV, SBM and IRO (Appendix C of ESRS 2) have been deleted, with a few exceptions maintained as separate Disclosure Requirements in topical standards (e.g. resilience in ESRS E1). \tThe requirement to disclose PAT for material IROs if adopted is maintained. But the requirement to disclose whether the undertaking plans to implement a PAT for material topics and timeline has been eliminated. The indication of which material topics are not covered by PAT is maintained. \tThe amendments have improved the connectivity between the disclosure of PAT and the description of IROs (now in ESRS IRO 2) to which they relate. They have also improved the ability to disclose information at a higher aggregation level than the material IROs, if this reflects the way IROs are managed.   Question Do you agree that these proposed amendments strike an appropriate balance between (1) prescriptiveness of the requirements and preparation effort from the one hand, and (2) need for relevant and comparable information from the other?","I agree"]
["Survey","Accountability Counsel","NGO","United States","12.","New guidance in ESRS 1 on how to consider remediation, mitigation and prevention actions in assessing materiality of negative impactsRationale for the changes To address a frequent  implementation  question and an area of divergence  in practice, new guidance has been introduced (ESRS 1 paragraphs 34 to 36 and Appendix C; Basis for Conclusions (BfC) Chapter 8) on how to consider implemented remediation,  mitigation  and  prevention  actions  in the DMA (the so called “gross versus net” issue). The EFRAG SRB has prioritised the guidance on impacts, as in financial materiality there is already reporting experience which can be leveraged.Description of the changes Appendix C, which has the same authority as other parts of the Standard, illustrates how to perform the assessment, i.e. before or after the actions that have been taken and have reduced the severity of the impact. The new guidance specifies how to treat actions in DMA differentiating ‘actual’ from ‘potential’ impacts.  It also differentiates the current reporting period from the future reporting periods (the latter is relevant as impacts of previous years that are material are also to be reported in the current period). For impacts that are assessed as material, the respective actions are reported (which also include policies implemented through actions).  Actual impacts are assessed for materiality before the remediation actions in the reporting period when they occur, while in future periods they are not reported if fully remediated. For potential impacts, when the undertaking must maintain significant ongoing actions to contain severity and/or likelihood below the materiality level, the impact is assessed before the actions are reported. This provision has been introduced to deal with cases such as health and safety negative impacts in highly regulated industries.Key discussion points at EFRAG SRB level  Some of the EFRAG SRB members consider the added guidelines excessively complex. The approach to disregard implemented actions when assessing materiality of potential impacts, if there are significant ongoing actions, has been the source of split views in the EFRAG SRB. The members that supported the inclusion of this provision considered that it would be inappropriate to conclude that due to the high level of prevention and mitigation standards in a sector, a given topic is not reported. On the contrary, other members think that this gross approach to potential impacts will result in excessive reporting.Question If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on Paragraphs 34 to 36 and Appendix C of ESRS 1, in Part 3 to avoid duplication of input. Your comments on Paragraphs 34 to 36 and Appendix C of ESRS 1 can only be provided here. Do you agree that the new guidelines clarify how to consider remediation, mitigation and prevention implemented actions in the DMA, contributing to more relevant and comparable reporting?","I agree","We commend the development of guidelines that instruct regulated entities to approach disclosure of potential and actual adverse impacts distinctly from actions taken to remedy, mitigate, and prevent harm. Addressing the possibility that regulated entities may seek to report only on net impacts, the guidelines stand to limit reporting that misrepresents or obscures  instances of serious harm and undermines the ability to assess the effective implementation of due diligence and human rights policies.   We encourage further instruction under Paragraph 34  as to need to report on whether and how remediation actions were developed in consultation or collaboration with adversely impacted people. Reporting on the extent of stakeholder engagement in the development of remedy would be helpful to better assess whether solutions to address issues are truly durable and sustainable. We recommend the following language, to follow the sentence \"Where the impact is deemed material based on this assessment, the undertaking shall disclose the remediation actions undertaken and their expected or actual outcomes\":  Disclosure on remedial actions shall detail how the interests of stakeholder groups were considered and incorporated, and how those groups are engaged to track the implementation and outcomes of remedial actions."]
["Survey","EARTH PBC","Consultant (including software vendor)","United States","18.","Relief for lack of data quality on metrics (ESRS 1 paragraph 92) Amended ESRS have introduced the ‘undue cost or effort’ relief for all the elements of the reporting, from the identification of material IROs to the calculation of metrics (paragraph 89 of ESRS 1), in line with IFRS S1 and S2, extending it to all metrics. In addition, paragraph 92 of ESRS 1 has introduced a provision applicable both to metrics in own operations and in upstream and downstream value chain.  This allows an undertaking to report metrics with a partial scope of calculation, when there are no reliable direct or estimated data to be used in the calculation. This relief does not exempt an undertaking from providing a disclosure, but it allows to disclose a calculation that includes only a partial scope. When using this relief, the undertaking shall disclose actions undertaken to improve the coverage of its calculation in next periods. This transparency is expected to provide sufficient incentive to improve the data quality and achieve a more complete scope in the calculation of the metrics. Accordingly, no time limit is included for the use of the relief. On this point, some EFRAG SRB members, while supporting the relief, considered it essential to include a time limit.   If you intend to provide feedback also on Part 3 of this questionnaire, please note that by answering this question, you will not be allowed to include comments on paragraph 92 of ESRS 1 in Part 3 to avoid duplication of input. Your comments on paragraph 92 of ESRS 1 can only be provided here. Do you agree that the proposed relief for lack of data quality on metrics strikes an acceptable balance between providing the necessary flexibility for preparers and avoiding undue loss of information?","I partially agree and partially disagree","The relief for partial scope calculation when reliable data is unavailable (ESRS 1, paragraph 92) addresses a real problem, but the solution misses the fundamental issue: value chain data gaps exist because companies lack direct connections to frontline operations. Traditional supply chain monitoring relies on intermediaries—suppliers, subcontractors, agents—who control information flows. These intermediaries have incentives to filter or manipulate data. The result: companies genuinely cannot obtain reliable metrics for Scope 3 emissions, labor conditions, or environmental impacts. Smartphone proliferation is eliminating this structural barrier. Frontline workers—fishers documenting catch locations, farmers tracking harvest activities, factory employees reporting working hours—can now report directly to forward-facing brands via smartphone with GPS-tagged evidence. This bypasses information gatekeepers entirely. Real-world validation: P&I insurance clubs now require continuous monitoring as insurance conditions because traditional audit data proved unreliable. Direct worker reporting provides the data quality that periodic supplier questionnaires cannot deliver. The relief without time limit concern: Some EFRAG SRB members rightly worry that unlimited relief removes incentive to improve data quality. However, this assumes data quality improvement requires extensive effort. When brands establish direct digital links with frontline workers, data quality improvements happen rapidly and cost-effectively. Recommendation: EFRAG should clarify that paragraph 92 relief is intended for genuine data unavailability, not avoidable gaps. Explicitly state that technology-enabled continuous monitoring via direct worker connections represents reasonable effort to improve data quality. Companies should not claim \"undue cost\" for implementing smartphone-based reporting systems that cost less than traditional audit programs while delivering superior data quality. The relief should encourage rather than delay adoption of direct monitoring capabilities."]
["Survey","Malta Institute of Accountants","Auditor","Malta","17.","Burden reliefs and other suggested clarificationsRationale for the changes The Amendments introduced several horizontal reliefs (i.e. applicable across different requirements) that were suggested in the input gathered from preparers. They are expected to contribute substantially to the reduction in the overall reporting efforts, beyond the datapoints reduction. These Amendments are described as Lever 5 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum did not explicitly mention the reliefs, but the letter of the EC dated 5 May 2025 recommended including those foreseen in the ISSB’s IFRS sustainability disclosure standards (IFRS S1 and S2). The Explanatory Memorandum nevertheless included the following objective (page 5): [the simplification] will also make any other modifications that may be considered necessary, considering the experience of the first application of ESRS. The revision will clarify provisions that are deemed unclear. It will improve consistency with other pieces of EU legislation. Description of the changes EFRAG has implemented the following changes: The relief “undue cost or effort” has been introduced, including for the calculation of metrics. \tA relief for lack of data quality has been introduced for metrics (ESRS 1 Paragraph 91), allowing to report a partial scope and disclosing actions to improve the coverage in future periods. \tThe systematic preference for direct data as input to the calculation of value chain metrics has been removed and undertakings may use direct data or estimates depending on practicability and reliability (ESRS 1, Paragraph 91). \tUndertakings may exclude from the calculation of metrics their activities that are not a significant driver of IROs (ESRS 1, Paragraph 90) and may exclude joint operations on which they do not have operational control when calculating environmental metrics other than climate (ESRS 1, paragraph 60). \tDisclosure about resilience is now limited to risks only and limited to qualitative information only (ESRS 2, Paragraph 24 and ESRS E1, Paragraph 21). \tWhen disclosing financial effects, the information on investments and plans is now limited to those that are already announced (ESRS 2, AR 16 Paragraph 23(b)). \tA new relief for acquisitions (disposals) of subsidiaries has been introduced (ESRS 1 Chapter 5.4) allowing to include (exclude) the subsidiary starting from the subsequent (from the beginning of the) period. \tFrom October 2024 to February 2025, several implementation issues were identified in the EFRAG ESRS Appendix dedicated to the Q&A implementation platform (Chapter of Basis for Conclusions (BfC)). These issues have now been addressed by clarifying the corresponding provisions.  Following the EC representatives’ recommendation, EFRAG did not include additional relief for commercial sensitive information, pending the changes of level 1 regulation, where this issue is being considered.Question EFRAG considered how to improve consistency with other pieces of regulation. Considering what can be achieved in these Amendments (as opposed to what requires modification by the other regulation) EFRAG gave priority to the SFDR regulation. Please refer to question 28 if you intend to comment on this aspect. Other selected changes to enhance consistency are described in the Log of Amendments for each standard.   Please note that some of the reliefs described above go beyond the ones in IFRS S1 and S2 described in question 21 below. As interoperability with IFRS S1 and S2 is specifically addressed in question 21 should be commented upon there. Please also refrain here from comments on the options proposed for quantitative financial effects, as question 17 is specifically dealing with them. Do you agree that these proposed Amendments provide sufficient relief and strike an acceptable balance between (a) responding to the stakeholders’ demands for burden reliefs and (b) preserving the transparency needed to achieve the objectives of the EU Green Deal, as well as interoperability with the ISSB’s IFRS S1 and S2?","I partially agree and partially disagree","We are in agreement with the majority of the reliefs which have been introduced, particularly relief 7. Agreed with flexibility for preparers due to undue cost and effort."]
["Survey","European Securities and Markets Authority (ESMA)","European supervisory authority","France","15.","Improved understandability, clarity and accessibility of the StandardsRationale for the changes The Amendments have reorganised the content of the requirements, clearly separating the mandatory from the non-mandatory ones, and eliminating the “may” disclose provisions, which proved to be problematic to understand. These Amendments are described as Lever 4 in the Basis for Conclusions (BfC) (Chapter 4). The Explanatory Memorandum (page 5) identified the following objective for this lever: simplify the structure and presentation of the Standards. Description of the changes To achieve this objective, EFRAG has implemented the following changes: “May disclose” datapoints have been all eliminated. \tAll the “shall disclose” datapoints are now in the main body of the standard (no more datapoints in AR) and mandatory application requirements are relocated below the DR to which they belong (and below each Chapter in ESRS 1), covering ‘how to disclose’ guidelines. \tLanguage of the Standards has been improved for understandability, conciseness and consistency of ESRS.   Question Please focus your considerations only on the mandatory content of the Exposure Drafts. The following question covers the Non-mandatory Illustrative Guidance (‘NMIG’). If you intend also to provide feedback on Part 3, when providing your comments, please refrain from duplicating the comments that you will provide at Standard or DR level. Do you agree that these proposed amendments achieve the desired level of clarity and accessibility?","I partially agree and partially disagree","21.\tESMA partially agrees and partially disagrees with some of the proposed amendments aiming at improving the understandability, clarity and accessibility of the ESRS. ESMA generally supports the increased clarity between mandatory and non-mandatory requirements and the removal of most of the \"may\" requirements. These steps contribute to improving the overall usability of the ESRS. However, we have also identified some practical issues relating to the clarity/understandability of the proposed amendments. These issues are further explained in our detailed response (paras 22-40) and relate to: the use of the terms \"shall consider\", the use of reminders in topical standards relating to cross-cutting principles set out in ESRS 1, the proposed location of Application Requirements, aspects relating to the ease of navigation across the standards, clarity on the articulation between IROs and topics/sub-topics in ESRS 1 and ESRS 2 and the clarity of ESRS 1 requirements relating to group reporting vs. subsidiary reporting."]
["Survey","European Securities and Markets Authority (ESMA)","European supervisory authority","France","21.","Enhanced interoperability with the ISSB’s standards IFRS S1 and S2Rationale for the changes EFRAG has implemented several changes to enhance the level of interoperability with the ISSB’s standards IFRS S1 and S2.  These amendments are described in Lever 6 of simplification in the Basis for Conclusions (BfC) (see Appendix 6). At the same time, however, the Amendments implemented for simplification reasons affect the level of interoperability with IFRS S1 and S2, as resulting from the joint EFRAG IFRS interoperability guidelines (May 2024). For example, reliefs beyond those in IFRS S1 and S2, described above, negatively affect interoperability. One of the Explanatory Memorandum (page 5) objectives is to further enhance the already very high degree of interoperability with global sustainability reporting standards. EFRAG prioritised the interoperability with IFRS S1 and S2, following the majority input gathered in the public call for input and outreach.Description of the changes To achieve this objective, EFRAG implemented the following changes, which aim to achieve a higher level of interoperability while being compatible with the objectives of the Amendments. In line with IFRS S1, emphasis has been put on ESRS being a fair presentation framework; materiality of information is now as general filter for the reported information. \tTo remove one of the main interoperability differences, the ESRS E1 GHG emission boundary has been replaced by the financial consolidation approach (ESRS E1 AR19), aligned with the financial control approach in the GHG protocol, while a separate disclosure based on operational control is now required (and aligned with the corresponding disclosure in the GHG protocol) only for entities with more complex ownership structures (ESRS E1, AR 20). \tThe IFRS reliefs (undue cost or effort, disclosure of ranges for quantitative financial effects) have been implemented, with the exception of the one on omitting commercially sensitive information about opportunities (pending the outcome of Level 1 discussions), the one allowing to omit Scope 3 GHG emissions when impracticable and the one allowing to omit quantitative financial effects when the undertaking does not have the necessary skills (please note that the relief on anticipated financial effects is treated in question 20). \tThe implementation of reliefs that go beyond the ones in IFRS S1 and S2 results in new interoperability differences (see question 16). \tLanguage for requirements that are common to ESRS and IFRS S1 and S2 has been aligned whenever possible with the one in IFRS S1 and S2, in ESRS 1, 2 and E1. \tThe reference to SASB Standards and IFRS Industry-based Guidance as a source of possible (“may consider”) disclosure when reporting entity-specific sector information is now a permanent feature (before it was temporary, i.e. until the issuance of ESRS sector standards). \tThe datapoint reduction resulted in the elimination of 7 “shall” datapoints aligned with ISSB standards described in Basis for Conclusions (BfC) (Chapter4). \tSeveral changes have been introduced to further advance interoperability in ESRS E1 (Basis for Conclusions (BfC), Chapter 4). Question Do you agree that these proposed Amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives?","I disagree","57.\tESMA disagrees that the proposed amendments achieve an appropriate balance between increasing interoperability and meeting the simplification objectives. While the ED increased interoperability with IFRS S-standards in some respects, ESMA believes that the areas of possible departure from the ISSB standards are so severe that they would undermine the overall interoperability for reasons that are unrelated to the specificities of EU policy objectives and which are likely to result in additional costs for undertakings. We provide additional comments in our reply in paras. 58-60."]
["Survey","European Securities and Markets Authority (ESMA)","European supervisory authority","France","33.E_1.","ESRS E1:33. Overall feedback per standard The 12 ESRS Standards have been simplified. The Glossary (Annex II to the 2023 ESRS Delegated Act) has been amended to reflect the changes in the Standards. This includes the reduction of datapoints, the clarification of several provisions that created implementation issues, the enhancement of readability and streamlining of their structure and content. Amendments to the 12 Standards have been designed and implemented to achieve a substantial reduction in reporting efforts, while maintaining the core content that is needed to meet the objectives of the European Green Deal. Please note the following requirements that were not changed in the Amended ESRS as recommended by the EC representatives, as they are subject to ongoing developments on level 1 regulation: 1. Definition of value chain for financial institutions (ESRS 1);  2. Exemption from consolidating subsidiaries by undertakings that are financial holdings (ESRS 1); 3. Relief for omission of confidential/sensitive information (ESRS 1); 4. Phasing-in provisions (ESRS 1); 5. Clarify the meaning of ‘“compatibility with 1.5 degrees’” for the Transition Plans disclosure (ESRS E1). In this question you are allowed to provide your overall opinion on the level of simplifications achieved per each standard. You can choose to reply to one or more of the Standards. If you intend to comment also at level of single DR in Part 3 of this questionnaire, you are kindly invited not to repeat the same content twice (here and in Part 3). You can access the Exposure Drafts of the Revised ESRS and the amended Glossary at this link. In case you would like to see the rationale behind the amendments, you can access the Log of Amendments and the markup of the Annex II (Glossary) at this link.Do you agree that the proposed Amended ESRS strikes an appropriate balance between the need for significant simplification and meeting the core objectives of the European Green Deal?","I partially agree and partially disagree","102.\tESMA partially agrees and partially disagrees that the proposed revisions to ESRS E1 strike the right balance between the need for significant simplification and meeting the core objectives of the EU Green Deal. We provide critical comments at disclosure requirement or paragraph level below, especially regarding transition plan and targets disclosures. These comments will be reflected in the Section 3 of the EFRAG questionnaire."]
["Survey","European Securities and Markets Authority (ESMA)","European supervisory authority","France","35.ESRS2_IRO-2."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","94.\tThere is inherent flexibility in the materiality assessment process on the granularity and the setting of thresholds and ESMA sees the resulting granularity of IROs as a matter of practice which will most likely converge in the medium term. Having an additional flexibility on the description of the IROs risks undermining the transparency of the materiality assessment process and could lead to inconsistencies with the objective of sustainability reporting as expressed in ESRS 1 par. 6 \"to present fairly the undertaking's material impacts on people and environment, as well as the material sustainability risks and opportunities\". As a consequence, ESMA recommends having clear limitations to the level of aggregation allowed in par. 28 related disclosures.\" \"95.\tIn addition, considering the increased flexibilities in grouping of IROs and presentation, ESMA thinks that the IROs should be clearly disclosed as related to one or several ESRS sub-topics, where relevant, or topics or signposted as related to entity-specific disclosures as part of their description. This could be part of the table proposed in AR 25. ESMA would be in favour of this table being a mandatory requirement rather than a voluntary one. See also the responses to questions 13 and 15 on this issue.\" \"96.\tIRO-2 par. 28 e: Regarding the table of EU datapoints, an option to refer to the datapoint as \"non applicable\" in addition to \"non material\" could be introduced, as it would fit better with some of the disclosures (e.g., SBM-1 par 17 c) and was used by some Wave 1 undertakings in their 2025 disclosures. The circumstances in which these different notions should be used could be clarified in an Application Requirement.","ESRS2","IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement",""]
["Survey","European Securities and Markets Authority (ESMA)","European supervisory authority","France","35.E1-9."," Do you agree with the amendments of this chapter? ","I partially agree and partially disagree","112.\tE1-9: ESMA's view is that the concept of GHG neutrality claim (par. 37) should be defined in the Glossary, where it should be specified that the concept covers all types of claims, including neutrality targets. 113.\tESMA also regrets the removal of all reference to net-zero targets from the standard. Such targets are widely used by issuers in some constituencies where supervisors could note improved disclosures and reduced instances of greenwashing in the 2025 sustainability statements. While ESMA agrees that a specific disclosure on how residual emissions will be addressed poses reporting challenges and should be removed at this stage, the concept of net-zero target itself should be defined and disclosure, where applicable, re-introduced, for instance through broadening par. 37. The definition of net-zero targets should clarify that all types of removals (removals in the value chain, as well as carbon credits of the removal type) are allowed for the neutralisation of residual emissions step.","E1","Disclosure Requirement E1-9 - GHG removals and GHG mitigation projects financed through carbon credits",""]
["Excels","ASD","","",null,null,"I disagree","Replace the \"first 3 years\" by \"3 years after the first year of mandatory reporting for wave 2 and wave 3 undertakings\" to ensure a level playing field.","ESRS1","ESRS 1  - 10.1 Transitional provision related to Chapter 5 Value chain","122."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","G1: Merge protection of whistle-blowers into anti-corruption and bribery, but keep separate from Culture as they cover legal requirements and not set of values and beliefs expressing goals.\n\nG1: Keep Animal welfare a separate topic, as it is not only a bout values and beliefs expressing goals but about protecting living creatures. The topic is especially important for agriculture, food and lether industries, and influences consumer choices (and even more so with vegan consumers). (Corporate culture expresses goals through values and beliefs. It guides the undertaking’s activities through shared assumptions and group norms such as values or mission statements or a code of conduct.) Even though a code of conduct can include many different topics, including diversity, tolerance, etc, legal requirements and protection of living creatures go beyond norms and shared assumptions expressed in a mission statement or code of conduct.","ESRS1","ESRS 1  - 1. ESRS Standards, reporting areas and drafting conventions ","9."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I partially agree and partially disagree","This new principle of \"fair presentation\" is generally welcomed. However, it must not lead to the omission of important topics that are necessary for complete, meaningful, comparable and auditable sustainability reporting under this guise.","ESRS1","ESRS 1  - 2. Fair presentation and qualitative characteristics of information","16."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","The presentation gives the impression that the entire topic standard is to be reported when the topic (through at least one  sub-topic) is material. This should be clarified at sub-topic level.","ESRS1","ESRS 1  - 3.2 Interaction between topics to be reported and material impacts, risks and opportunities","22."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","The scope of the value chain activities included in the CSRD impact materiality assessment and the scope of the “chain of activities” subject to due diligence obligations under CSDDD should be aligned. The differences in the activities covered by CSDDD and CSRD creates unnecessary, duplicative, and burdensome variations in the process for identifying and assessing a company’s sustainability impacts for reporting versus due diligence purposes. Similarly, the definition of \"business partner\" and \"business relationship\" should be the same for both CSRD reporting and CSDDD due diligence purposes. This paragraph should be revised to explicitly state that material impacts are impacts that an undertaking causes, contributes to, and/or is directly linked to, consistent with the U.N. Guiding Principles on Business & Human Rights (UNGPs). This language from the UNGPs is referenced in other parts of the Amended ESRS (e.g., ESRS S1 - 3, AR 6). The language should also be included in the description of the DMA process in order to more clearly delineate the boundaries of an undertaking's assessment of impacts, risks, and opportunities.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","30."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","There is confusion between mitigation measures and remediation measures. In addition, further confusion arises when considering how to handle subsequent years. Additionally, there is still no clear framework for accurately assessing severity. This lack of consistency can result in the same impact being deemed highly significant by one company and barely relevant by another, even when both operate in the same country and the analysis focuses solely on gross impact. Additionally, Given that \"remediation\" is defined as including actions that \"counteract\" (i.e., mitigate) a negative impact, the third sentence should be amended to clarify that remediation actions are not considered in relation to actual negative impacts only to the extent that they occur after the impact occurs. In the fourth sentence, remediation actions should only be required to be disclosed if material.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","agreement to include explicit reference to fair presentation","ESRS1","Chapter 2 Fair presentation and QC",""]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","BDEW is fine with current definition, more precision helpful.","ESRS1","","par 16 ff"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","\"Affected stakeholders\" - do we need to clarify that (although performing a thourough assessment), there might be affected stakeholders, a reporting company might not be aware of (e.g. by them not reaching out to the reporting company)?  - impact as general starting point for IRO DMA - \"although there may also be material RO that are not related to undertaking's impacts\" - is this sufficiently clear regarding Impacts vs. RO? ","ESRS1","Affected stakeholders","par 33"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","51 lists \"locations, water basin, site, asset… \" as though they are all different aspects to consider; in AR 23 \"by location\" is specfified as \"by location - such as by site, water basin or local ecosystem\", not as though if you differentiate by location, it can be one of the following - why is \"location\" needed then? ","ESRS1","","par 51 and AR 23 for par 51"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","We assume it would be a better option for e time horizon definition \"according to financial reporting\"\npar 77 (a) now includes a \"definition\" for \"short-term time horizon\" being \"the length of the periood adopted for its financial statements; apparently this was on Q&A Platform; however: why is this reference to f/s needed? It is the same period that is adopted for the sus statement... so basically it is the reporting period... why not say so? Which other \"period adopted for f/s\" could there possibly be? Or is this a misunderstanding? Is this referring to Management Report and the \"short-term\" definition applied there? Also: still the question remains to FA NB whether IFRS alignment (i.e. time horizons being entity specific) should be considered instead of the specific requirements? ","ESRS1","6. Reporting period, base year and time horizons","par 77"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","Very helpful appendix, but clarity should be increased for cases with \"significant ongoing mitigation actions\" - reporting only, if there is a residual material impact.\nThis appendix and the text in the standard (par 34 et seq) require more consistency / harmonisation to avoid misinterpretations or discussions with auditor!! see above.","ESRS1","Appendix C - Assessing actual and potential negative impacts for materiality",""]
["Excels","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States",null,null,"I disagree","Reporting on material topics not covered by the ESRS is defined as mandatory (shall) – whilst reporting of additional issues may be beneficial, it should not be mandatory","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","10."]
["Excels","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States",null,null,"I disagree","Whilst companies routinely benchmark their performance against peer companies, it is not reasonable to make this a mandatory requirement for the reporter.  Full information is unlikely to be available in the public domain prior to the reporting period.  Whilst CSRD reporting would provide a good source of information, company comparisons should be down to users of the data, not mandatory for reporters – this is the role of ratings agencies, investors, regulators, not the companies themselves","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","11."]
["Excels","Society for Corporate Governance","Business association (other than association of financial institution)","United States",null,null,"I disagree","To promote interoperability and minimize unnecessary costs and burdens, ESRS should afford companies the flexibility to draw their organizational boundaries using the equity share approach or the financial or operational control approaches as permitted under the GHG Protocol and IFRS S2.EFRAG’s proposed revision creates significant misalignment between E1 and key emissions reporting standards and unnecessarily burdens the multitude of companies that use the operational control or equity share approaches for their organizational boundaries and would need to recalculate their emissions solely for the purposes of complying with the CSRD. The GHG Protocol and IFRS S2 provide companies the flexibility to draw their organizational boundaries using the equity share approach or the financial or operational control approaches (see section A.3 of this analysis). Indeed, the GHG Protocol explicitly states that it “makes no recommendation” as to which approach a company should use for voluntary public GHG emissions reporting (see p. 20), and this flexibility should carry over to ESRS GHG emissions reporting given the competing interests that a company may need to consider in selecting its optimal approach (see p. 20-21) and to promote interoperability and associated reduction of compliance costs and burdens. ","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","AR 18"]
["Excels","Materiality","Consultant (including software vendor)","Poland",null,null,"I disagree","In our experience, this sentence has been subject to different interpretations. It is clear that nature is indeed a silent stakeholder, as it cannot speak for itself. However, is it mandatory to consider its needs in the double materiality analysis for example by reviewing scientific reports and research findings? The wording “may be” leaves room for interpretation that it is not, which suggests that further clarification is needed. \"May be\" should be replaced with \"shall be\".","ESRS1","ESRS 1  - 3.3 Double materiality assessment","AR 10"]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I disagree","Suggest to avoid the term 'primary' users which suggests a hierarchy amongst different users ","ESRS1","ESRS 1  - Objective","4. (a)"]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I partially agree and partially disagree","Exclude own operations from this relief ","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","91."]
["Excels","GKK Partners","Consultant (including software vendor)","Germany",null,null,"I disagree","This would required a structured consideration of the stated factors and \"included information\". If not accessible for the users, at least the undertaking should provide a clear structure, so that external assurance providers could rather comparatively consider this information.","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","88."]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","lack of a definition of fair presentation will likely lead to different interpretations","ESRS1","ESRS 1  - 2. Fair presentation and qualitative characteristics of information","16."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I disagree","The wording of this paragraph suggests that the scope of sustainability-related risks and opportunities has been broadened to include all “financial risks and opportunities” whereas the focus of the ESRS is on sustainability matters.","ESRS1","ESRS 1  - 1.2 Drafting conventions","12. (b)"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I agree","We support the retention of the steps for assessing impact materiality.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 5"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","The third paragraph should read ‘impacts, risks and opportunities that may be material’ instead of ‘material potential impacts, risks and opportunities’. Both potential and actual impacts need to be considered in the materiality assessment.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","AR 17"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Table of Content: Appendix C should be before Appendix B since \"assessing impacts\" are part of DMA and thus more related to App. A.","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","7."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I agree","This amended requirement will help for faithful presentation and comparable information to stakeholders generated by the reporting of different reporting undertakings.","ESRS1","ESRS 1  - 5.1 Reporting undertaking and own operations","59."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","While we support the general relief for metrics related to ESRS E2 to E5 in case of a joint operation, it remains unclear in which case a parent company may not have (partially) operational control over a joint arrangement although it should have financial control (otherwise this would not represent a joint operation). In addtion, the relief could be also extended to ESRS Sx and G1 since the data gathering for metrics related to these standards may also be burdensome and complicated within a joint operation. We would recommend further specification.","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","92."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Defining the long-term horizon as >5years, without limiting it to a certain number of years (e.g. >5-10 years) makes it very challenging to evaluate and estimate the severity and likelihood of Impacts, Risks and Opportunites. Due to the volatile nature of different factors that influence these IROs it is often very challenging to estimate the severity & likelihood of an impact, if the time period has an open end.  We therfore recommend to  limit the long-term horizon, e.g. to >5-10 years in order to generate meaningful outcomes.","ESRS1","ESRS 1  - 6.2 Time horizon: definition of short-, medium- and long-term for reporting purposes","78."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","While the sentence \"ARs also include text where the term ‘shall consider’ is used to indicate issues, resources or methodologies that the undertaking is expected to take into account or to use in the preparation of a given disclosure. \" tries to specify the use of \"shall consider\", it is a contradiction to para. 5 where it states that \"The ESRS do not mandate behaviour [...]\". A \"if applicable\" should therefore be added. Additionally, \"shall consider\" is not consistently applied as sometimes only \"shall\" is used (eg. ESRS E1 Ar 4 and 5).","ESRS1","ESRS 1  - 1. ESRS Standards, reporting areas and drafting conventions ","15."]
["Excels","UNICEF","NGO","United States",null,null,"I partially agree and partially disagree","UNICEF welcomes the reference to “available best practices and/or available frameworks and reporting standards” in the context of entity-specific and sector-specific disclosures. We encourage EFRAG to broaden the examples beyond GRI/IFRS to include other credible disclosure guidance published by multi-lateral and multi-stakeholder organizations. For example, companies can improve the quality of their child rights impact disclosures by using UNICEF’s guidance briefs for “Children as stakeholders at heightened risk of adverse impacts”,  “Children’s Rights and Double Materiality” , and “Reporting on children’s rights under the social standards” , as well as UNICEF’s \"Disclosure Recommendations for Corporate Reporting on child rights impacts in relation to the digital environment”. These resources and frameworks have all been created to be interoperable with ESRS; referencing their availability and increasing their profile will help ensure that companies make entity-specific and sector-specific disclosures about material impacts on children. See: https://www.unicef.org/reports/unpacking-childrens-rights-under-european-sustainability-reporting-standards and  https://www.unicef.org/childrightsandbusiness/workstreams/responsible-technology/reporting","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","11."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","See our comments to question 25 in Part 2 of EFRAG's survey.\n§ 16 indicates that fair presentation requires disclosure of \"relevant information that meets the conditions in paragraph 21\" which refers to the materiality of information. We believe this wording is inconsistent with QC 4 according to which materiality is an entity-specific aspect of relevance. Overall, we recommend that EFRAG align ESRS 1 with IFRS S1 wording to enhance interoperability between both reporting frameworks.","ESRS1","ESRS 1  - 2. Fair presentation and qualitative characteristics of information","16."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","We note that former § 67 under ESRS 1 has been modified so that it now no longer covers joint ventures that are proportionally consolidated (as it is the case, for example, in the consolidated financial statements under French or Spanish GAAPs). Based on this redrafting and on the definition of own operations provided under § 59, we understand that such joint ventures are part of the own operations, but we recommend that EFRAG further clarify this. This clarification would also be helpful for joint operations that are accounted for using a similar method under IFRS 11, consistently with the clarifications made by EFRAG in IG 2.","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","69."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I disagree","We strongly recommend deleting this § given that joint operations require, overall,  further investigation from EFRAG. Besides, the concept of operational control on which this § relies on  still lacks clarity in the ESRS. Finally, the way the relief is drafted seems to imply that the additive approach is still required in the revised ESRS, which is not the case based on the proposed ESRS E1 (and no other standard refers to operational control in the proposed revised set of ESRS).","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","92."]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I agree","For simple understanding of relation between IROs and topics, require a simple mapping table once per topic: list the material IROs driving the topic, or (if reporting at IRO level) the topic each IRO rolls into.","ESRS1","ESRS 1  - 3.2 Interaction between topics to be reported and material impacts, risks and opportunities","22."]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I partially agree and partially disagree","Add suggestion that undertakings clarify when qualitative information was used and when quantitative information was used. If no information available, provide an explanation. For financial institutions specify if they are compliant with IFRS S2. Clearer guidance from EFRAG on how the ESRS comply to the IFRS S2 and increase alignment is needed.  ","ESRS1","ESRS 1  - 3.3.2 Financial materiality assessment","AR 19"]
["Excels","BDO","Auditor","Belgium",null,null,"I partially agree and partially disagree","We support allowing a' top-down' approach as an option, which we think will simplify the DMA process as it is more in line with how the business is managed. We support the guidance provided in ESRS 1, section 3.5. We believe that in most cases all material IROs will be identified also using a 'top-down' approach. However, we think it would be useful to have some non-mandatory guidance on expected IROs for different industries to avoid overlooking material IRO/(sub-)topics. ","ESRS1","ESRS 1  - 3.3 Double materiality assessment","28."]
["Excels","UNEP-WCMC","NGO","United Kingdom",null,null,"I agree","We strongly recommend maintaining a double materiality approach – without this, many significant impacts and risks on nature will not be required to be reported, which will reduce the benefit from implementation of ESRS reporting. ","ESRS1","ESRS 1  - 3.1 Materiality of information as a general filter for reported information","21."]
["Excels","UNEP-WCMC","NGO","United Kingdom",null,null,"I disagree","Strongly recommend clarifying in the second sentence that information available “without undue cost and effort” includes new information that companies may need to collect to strengthen their understanding and management of impacts, risks and opportunities, which can be obtained with proportionate investment and effort. The current wording of the sentence implies information available “without undue cost and effort” is only the information that companies are already collecting. It is important to revise this to ensure ESRS drive improvements in how impacts, risks and opportunities are assessed and reported over time. IFRS definition of “undue cost and effort” also acknowledges that new information obtained in ways where cost and efforts of the company are balanced out by the benefits of improved information, is still considered as obtained “without undue cost and effort”. Given ESRS double materiality approach, the benefit of obtaining new information should be considered as benefit to company as well as people and nature.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","47."]
["Excels","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria",null,null,"I partially agree and partially disagree","Depending on the type of stakeholder different views prevail regarding the assessment of the gross-versus-net-perspective on potential negative impacts.\n\nWe welcome the differentiation between “gross-versus-net”-impacts. However, the dis-closure of impacts regarding “significant ongoing mitigation and/or prevention ac-tions” requires a more nuanced description. We expect diverse interpretations of the term “significant” and potential loss of material information. While illustrations are provided, companies will need to exercise careful judgment, which could lead to incon-sistencies. We suggest providing a decision tree/flowchart in addition to the explana-tion and providing concrete evaluation examples.\n\nAdditionally, we suggest a better alignment between Appendix C and the main text. The incorporation of the ISSB TIG-approach might be useful to ensure no material in-formation is omitted for net-considerations.\n\nFrom preparers’ perspective, a gross approach would lead to disclosures including hy-pothetical risks which are already effectively managed and therefore inflated disclosures and obscure truly material issues. Furthermore, Appendix C brings complexity into the DMA process. Therefore, the IRO-assessment should be done on net-basis and Appen-dix C removed.\n\nFrom auditors’ perspective, the new guidelines provide clearer instructions for the in-corporation of remediation, mitigation, and prevention actions into the DMA. This con-tributes to more relevant and comparable reporting across entities.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","35."]
["Excels","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria",null,null,"I partially agree and partially disagree","Previously 1.62 and 1.63 have been amended but do still not clarify the appropriate treatment of leased assets. We recommend amending it accordingly. To make it clear for the preparer, clarification needs to be streamlined with E1 requirements as well (i.e. former ESRS E1-6).  ","ESRS1","ESRS 1  - 5.1 Reporting undertaking and own operations","58."]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Any evaluation of potential negative impacts must be done taking into consideration ongoing mitigation and prevention actions which are considered as \"standard\" for a specific industry or sector. Otherwise topics undertakings would need to report on topics which in reality are not material.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","35."]
["Excels","Royal Hollway University of London","Academia","United Kingdom",null,null,"I partially agree and partially disagree","Many disclosures under IFRS do not involve numbers. However, when expressing materiality in terms of percentages, some auditors refer to 5% of profit. By contrast, “significant”, when defined numerically in IAS 28, means a 20% threshold. Thus, “material” appears to mean something smaller than “significant” when numbers are involved. It would be perverse if this did not also apply for non-numerical disclosures under IFRS. [continued below.]","ESRS1","ESRS 1  - 3.1 Materiality of information as a general filter for reported information","21."]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I agree","There is a typo \"The undertaking shall make every dt to ensure…\" ","ESRS1","ESRS 1  - 7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","101."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","Para. 27 lists usual internal and external sources of evidence and information that the undertaking may use in conducting a materiality assessment. Environmental managementsystems (e.g. ISO 14001 or EMAS) provide a useful basis for conducting the impact materiality assessment for environmental topics and should therefore be explictly listed here.","ESRS1","ESRS 1  - 3. Double materiality as the basis for sustainability reporting","27."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I agree","An important part of EFRAG’s mandate to revise the ESRS is to increase consistency with other pieces of EU legislation. For this reason, we urge EFRAG to maintain the possibility to incorporate information by reference from EMAS environmental statements (Regulation (EU) No. 1221/2009). ESRS 1 para. 119 should clarify that, in line with the FAQ issued by the European Commission in August 2024 (para. 71), that the validation of environmental information provided by EMAS Environmental Verifies can be considered to be at least at the same level of assurance as the CSRD limited assurance requirement.","ESRS1","ESRS 1  - 9.3 Incorporation by reference","119."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","We believe it is necessary to clarify that the exception provided for leases is applicable to all the disclosure requirements in the topical Standards and to the reporting of GHG emissions in ESRS E1 in particular, as this is a difference with the GHG Protocol on which ESRS E1 builds (when the financial control approach is used).","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","70."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I disagree","We note that in the course of the streamlining of ESRS 1, an important sentence under previous paragraph 113 has been deleted: \"These disclosures are not subject to the provisions of \nESRS, with the exception of this paragraph and the ﬁrst sentence of paragraph 115 of this standard.\" This sentence was key to explicit that ESRS requirements (notably the principle of materiality of information) do not apply to EU Taxonomy disclosures, such disclosures being covered by specific regulations and FAQs issued by the EC, which may contradict some ESRS principles or reliefs (e.g. the proposed relief on acquisitions / disposals in ESRS 1 contradicts FAQ 152 of the EC published in March 2025). \nWe note that having deleted this sentence from ESRS 1 will inevitably raise many questions in practice on whether ESRS 1 general principles such as fair presentation, the reliefs granted, etc. also apply to the EU Taxonomy information. We therefore believe that it is of the utmost importance to keep this sentence in the revised ESRS 1.","ESRS1","ESRS 1  - 8.1 General presentation requirement, structure and content of the sustainability statement","106."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","Para 87-89. We support the new relief on using available information available without undue cost or effort.","ESRS1","ESRS 1  - 7. Preparation and presentation of sustainability information","87."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","Sub-chapter 8.2 and 8.3 (para. 106-110)  Equinor welcomes the opportunity for flexibility in including additional disclosures stemming from other legislation which requires the undertaking to disclose sustainability information, additional disclosures that do not relate to a topic, the EU Taxonomy, executive summary and including detailed informaton about the calculation of its reported GHG emissions in appendices. ","ESRS1","ESRS 1  - 8.2 Presentation of additional information included in the sustainability statement","106."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","Note: This comment is to Appendix A, but appendicies were not listed in drop down menu. It is referred directly in ESRS1 para. 9\n\nWhile we support removal of examaples from sub-sub-topic level, we still belive that the proposed division of biodiversity and ecosystem topics in Appendix A to ESRS 1 for E4 Biodiversity and Ecosystems - separating drivers of change, state of species, ecosystem condition, and ecosystem services - creates challenges for materiality assessment and reporting. While the first element concerns the causes of biodiversity loss, the others reflect its consequences, effectively requiring undertakings to assess both sides of the same issue. Boundaries between species state and ecosystem condition are often unclear, and ecosystem services depend on both, making separate disclosures potentially redundant. This structure complicates double-materiality assessments by forcing preparers to evaluate pressures and outcomes simultaneously, increasing the risk of double counting, omissions, and inconsistent prioritisation. It also blurs accountability in reporting and hampers the development of a clear, decision-useful sustainability narrative. Although inspired by scientific “pressure–state–impact” models, the approach is difficult to operationalise in corporate reporting, and the challenges observed in the 2023 standard remain in the 2025 draft. ","ESRS1","ESRS 1  - 1. ESRS Standards, reporting areas and drafting conventions ","9."]
["Excels","Danish National Funding Mechanism","(National) standard setter","Denmark",null,null,"I partially agree and partially disagree","Partially disagree \nIt should be clarified that considerations on capital providers’ decision-making shall focus on information essential to protect and evaluate prospects of their assets, while strategic or ethical preferences of investors in their decision-making need not be considered, e.g. an investor’s zero-tolerance on certain ESG-matters. \nA criterion should emphasize that understanding is about getting a general impression of a subtopic and the related IRO and should be no more than what can be considered necessary by the undertaking to initiate a qualified dialogue. The level of aggregation and disaggregation shall be proportionate to the degree of severity of impacts.","ESRS1","ESRS 1  - 3.1 Materiality of information as a general filter for reported information","21."]
["Excels","Danish National Funding Mechanism","(National) standard setter","Denmark",null,null,"I partially agree and partially disagree","Partially agree\nIn our opinion the top-down and bottom-up approach should have equal footing and that the reporting entity can choose which of these between them without having do document that the result of the one not-used would not have been different from the method used as this would in reality require entities to apply both methods.  Therefore, it should be added in the last sentence that “, although documentation is not required”.  \nIn addition, EFRAG should add to the Basis for Conclusion that the two methods are deemed to result in the same outcome. ","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","AR 17"]
["Excels","Danish National Funding Mechanism","(National) standard setter","Denmark",null,null,"I partially agree and partially disagree","Partially agree \nESRS1-71 should be more clearly demarcated to assets in defined benefit plans, as an undertaking has no relationship to pension assets in defined contribution plans","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","71."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","In the sentence: ‘the undertaking may use in conducting a materiality assessment:’ the word ‘may’ is used. In our opinion, this construction will result in the listed sources being used selectively, while dialogue with stakeholders is a mandatory element of the DMA process, which derives from the due diligence process. We recommend a different sentence construction, indicating that the listed sources constitute a mandatory but not exhaustive list for use in the DMA process.","ESRS1","ESRS 1  - 3.3 Double materiality assessment","27."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","Very important information on how to identify material entities in the value chain that may be a source of material impacts, risks, and opportunities should be transferred from IG2 VC (point 28) to ESRS 1 as a supplement to the AR for this point. Many entities are not familiar with and do not apply the IG guidelines, considering them to be non-binding. However, the ESRS in its current wording leaves many ambiguities that have been clarified in the IG.","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","64."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","What about employees, non-employees, workers in the value chain, end users/consumers, customers? Perhaps \"affected stakeholders\" could be mentioned here as wel","ESRS1","ESRS 1  - Objective","4. (b)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","As may disclosures are still included, we would suggest to mantain the following:\n may disclose’ – indicates voluntary disclosure to encourage good practice.","ESRS1","ESRS 1  - 1.2 Drafting conventions","14."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Why the word \"grave\"has been replaced by \"serious\"?","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 7"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Does it mean that policies should also be identified while carrying out the DMA? This will include additional reporting requirements within the process","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 12"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","Please clarify the concept of \"entity-specific basis\"","ESRS1","ESRS 1  - 3.6. Determining the information to be reported in accordance with ESRS 2 and topical standards","49."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I agree","Minor typo: The undertaking shall make every dt to ensure that","ESRS1","ESRS 1  - 7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","101."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","In line 5, a reference to administrative, management and supervisory bodies' delegated bodies should be incorporated, as follows: the members of the administrative, management and supervisory bodies or their delegated bodies.\nAdditionally, the following sentence should be removed \"acting within the competences assigned to them by national law and having collective responsibility for that opinion, the\"","ESRS1","ESRS 1  - 7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","AR 35"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","The provision appears excessively complex, as evidenced by the fact that the amendment note is longer than paragraph 22 itself.","ESRS1","ESRS 1  - 3.2 Interaction between topics to be reported and material impacts, risks and opportunities","22."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","It does not provide a clear clarification of the meaning of “undue cost or effort” in the comment recorded in the log of amendments.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","46."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","The concept of “undue effort” should mean activities beyond regular business processes. However, since sustainability due diligence is itself defined as part of those processes, the notion becomes circular. For example, §47 states: “To identify material impacts, risks and opportunities, the undertaking shall […] use information prepared […] in conducting its sustainability due diligence […]”. This reference does not clarify what constitutes undue effort; instead, it reinforces the loop.\nIn practice, external auditors often suggest that due diligence should also cover indirect value chain relationships. If not, companies must document that a reasonable effort was made. This could imply gathering data from suppliers of suppliers or financed counterparts. Proof might simply be showing outreach attempts (e.g., email requests), but what counts as sufficient evidence remains highly debatable.\n§47 provides no guidance here. A clearer approach would be to explicitly state that tier 2+ relationships in the value chain must be considered in AR5.(a) and AR5.(b), while direct outreach to such entities is optional unless required by law. This clarification should be added in a new paragraph, and §47 should avoid referencing due diligence in defining undue effort.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","47."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","In principle, we agree with the position set out in ESRS 1 paragraph 70, according to which the impacts, risks and opportunities arising from the use of a leased asset exist irrespective of whether the asset is legally owned by the undertaking or leased. The lessee causes and contributes to the impact of the leased asset and must therefore report on such impacts in the course of its own operations during the lease term (e.g., Scope 1 and 2 emissions).\n\nHowever, we wish to point out that, in our view, the perspective of the lessor and the act of leasing itself has thus far been insufficiently addressed in this paragraph. In practice, the distinction between leasing and rental is often blurred, particularly in the case of operating leases with short durations or limited control. We therefore recommend that the lessor’s perspective be explicitly incorporated into ESRS 1 paragraph 70, in order to ensure consistent and transparent reporting across the entire value chain.","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","70."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nRedundant information that is sufficiently covered in ESRS 1 re/ qualitative characteristics and in ERSS 2 re/reporting areas.\nThis applies to all sustainability-related disclosures.\nSuggestion:\nDelete AR 1 for para. 11 in its entirety.","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","AR 1"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","The definition of “common categories of affected stakeholders” in AR 10, employees and/or workers’ representatives, suppliers, consumers or end-users, affected communities, persons in vulnerable situations, and nature, raises two concerns. First, previously identified relevant stakeholders do not necessarily fit into these categories, which restricts flexibility. An “other” category or clarification that additional categories are permissible would therefore be appropriate. Second, the term “persons in vulnerable situations” is not defined and requires further explanation.\n\nIn addition, AR 10 and AR 11 are inconsistent. AR 10 includes workers’ representatives within the list of affected stakeholders, whereas AR 11 distinguishes between affected stakeholders and their representatives. To resolve this, two options exist:\n\nOption 1: Amend AR 10 only, leaving AR 11 unchanged.\n\nOption 2: Amend both AR 10 and AR 11, clarifying that affected stakeholders may be represented by intermediaries. For example:\n\nAR 10: “…affected communities and persons in vulnerable situations and/or their representatives.”\n\nAR 11, sentence 2: “However, the undertaking may also seek direct input into its materiality assessment from affected stakeholders or their representatives (such as employee representatives or trade unions).”","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 10"]
["Excels","IMA-Europe ","Business association (other than association of financial institution)","Belgium",null,null,"I agree","If this reads in the way I'm interpretting it, companies are not expected to report on every single IRO that results from the DMA in order to report on that topic, selecting a few IRO would be sufficient. Further clarity would be required.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","46."]
["Excels","IMA-Europe ","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","In my opinion, not material information should not be in the sustainability statements. If the emphasis is on providing information relevant to the users of sustainability statements (users of general purpose financial reporting and other users of sustainability statements) adding not material information would obscure/distract these users from obtaining material information easily and reliably. Ultimately these additional stakeholders requesting this type of information might benefit from having this information reported in a medium that is more appropriate for them (not in the management report for example). That being said, I wouldn't use this clause, so if others feel strongly about keeping this provision with guidance in that's fine but I think we're deviating from the purpose of these statements which is clear material information only. ","ESRS1","ESRS 1  - 8.2 Presentation of additional information included in the sustainability statement","108."]
["Excels","Allianz SE","Insurance","Germany",null,null,"I disagree","The new guidelines introduce three additional assessment layers for the assessment of actual and potential impacts – (1) the need to perform an effectiveness test of actions, (2) the requirement to distinguish between significant ongoing vs. temporary actions, and (3) the necessary differentiation in the assessment and disclosures between current and future reporting years – all of which were not present in the set 1 ESRS. We expect a significant increase in reporting burden through these additional layers, as they require supportable evidence and will be subject to high auditor scrutiny. This would particularly penalize wave 1 companies that have already implemented a sophisticated and comprehensive materiality assessment process, methodology, and governance setup. As such, the introduction of the new guidelines is clearly against the European Commission mandate of simplification.\nOur suggestion is to completely remove the new guidelines on gross vs. net, i.e. paragraphs 34/35 and Appendix C of ESRS 1, and give the market practice time to evolve, which by itself will address currently existing divergence in practice.\nRegarding paragraph 36 and the clarification of positive impacts, we agree with the addition, as it provides helpful guidance on the matter of understanding positive impacts.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland",null,null,"I partially agree and partially disagree","There needs to be a timeframne, but a reasonable timeframe to improve data quality - maybe 5 years. ","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","90."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","\"Impacts, risks and oportunities\" should be put in bold in the first sentence and not in the part under letter (a).\nIt should be clarified that once impacts, risks or opportunities are identified as material all time horizons should be analyzed for the purposes of drafting the sustainability statements.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","AR 18"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","\"every dt to ensure\" should be amedned (into \"every effort to ensure\"?)","ESRS1","ESRS 1  - 7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","101."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I disagree","This should not apply to own operations.","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","91."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I disagree","The provision allowing companies to conclude on the materiality of topics or sub-topics based solely on their business model, value chain, peer analysis, and strategic priorities is risks creating inconsistent practices. The ESRS should clarify where thresholds are expected to be set. ","ESRS1","ESRS 1  - 3.3 Double materiality assessment","AR 18"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","A distinction is made between the materiality of information for primary users of general purpose financial reports and users of general purpose sustainabilty statements. In this distinction, primary users of general purpose financial reports use sustainabitliy information to make decisions based on these reports, and users of general purpose sustainablity reports only use sustainabitliy information to understand the undertaking's IRO's. This distinction is not true and leads to an unequal distinction between users of financial reports and sustainability statements. DASB believes that users of general purpose financial reports also use information on the undertaking's IRO's and users of general purpose sustainability statements also use sustainbility information for decision making. We suggest to use only primary users under 21 a) en 21b) instead of a distinction between primary users of general purpose financial reporting and general purpose sustainability statements.","ESRS1","ESRS 1  - 3.1 Materiality of information as a general filter for reported information","21."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Delete - not a a pragmatical disaggregation level","ESRS1","ESRS 1  - 3. Double materiality as the basis for sustainability reporting","AR 23"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","With the removal of sub-sub-topics from Appendix A of ESRS 1, we seek clarification on how. in particular, top-down materiality assessment should be applied in such cases. For example, if a specific impact, risk, or opportunity that was previously captured under a sub-sub-topic (e.g., under ESRS S1) is now found to be material, should this lead to a disclosure at the sub-topic level (e.g., \"Working conditions\")? In other words, where the materiality of a sub-topic is determined based primarily on the materiality of one of its former sub-sub-topics, is it now expected that reporting should occur on the broader sub-topic level?\n\nClarity on this point would help ensure that disclosures remain relevant and decision-useful, without introducing disproportionate reporting burdens.\n- CHANGE. Attaching the deleted sub-sub-topics in brackets after the sub-topics will effectively increase the reporting burden as it still necessitates considering all these in the DMA but makes it harder to apply materiality to exclude information","ESRS1","ESRS 1  - 3.3 Double materiality assessment","AR 17"]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I agree","Agree with the addition of fair presentation as an overarching principle and including qualitative characteristics of information more prominently in the standard. Our experience supports the view that currently the information provided is in some cases of little benefit for users, and giving qualitative characteristics of information stronger prominence could potentially address this shortcoming.","ESRS1","ESRS 1  - 1. ESRS Standards, reporting areas and drafting conventions ","18."]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I disagree","This is difficult to understand and should be edited for clarity. We would strongly oppose any relief which would allow companies to only consider part of their value chain on the grounds of \"undue cost and effort\". This kind of approach would be against international business and human rights standards such as UNGPs and OECD Guidelines.","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","87. (c)"]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","Glossary: The definition of \"actual impacts\" should not only those that have already occured but also those that are currently occuring. Change definition to: \"Impacts that have already occured in the reporting period or in prior years or those that are currently occuring in the repporting period.\"","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I disagree","This paragraph in conjunction with proposed paragraph 69 entail lack of consistency between metrics. We believe that the operational control criterium should be consistent across all material topics, as it will allow clear interpretation of business relationships, i.e. all entities out of operational control should be included in the value chain. ","ESRS1","ESRS 1  - 5.4 Relief for acquisitions and disposals","92."]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I disagree","What is expected in terms of disclosure with regards to \"dependencies\" and the financial effects, especially those which are not recognised in the financial statements? Does the financial materiality apply to these financial effects?","ESRS1","ESRS 1  - 3. Double materiality as the basis for sustainability reporting","14."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","This further complicates the analysis, as the impacts would need to be assessed primarily for materiality (§31-32), and secondarily based on net versus gross effects.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","If peer analysis is used, further investigation is necessary to include or exclude a topic from the sustainability statement as an undertaking should only report on impacts, risks and opportunities related to its own business model and strategy.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","48. (a)"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The sustainability information is consolidated based on the financial consolidation, this § brings further confusion in this statement as it takes about potential minority shares that are not financial consolidated but would have to be considered in sustainability data as part of \"business relationship\".","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","68."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","\"(b) could reasonably be expected to have been obtained….\", we suggest that the previous used term \"without undue cost of effort\" to be used in here instead of reasonable.","ESRS1","ESRS 1  - 7.7 Reporting errors in prior periods","AR 33"]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The paragraph relating to incorporation by reference provides unclear indications and limits the possibility of using this tool. This provision should be simplified to enhance its usability, perhaps also providing the possibility of reporting the most detailed information on the company website.","ESRS1","ESRS 1  - 9.3 Incorporation by reference","1."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Overall, the summary of the sub-sub-topics at sub-topic level is welcomed. However, the addition in brackets and the naming of several topics indirectly maintains this fine distinction. The sub-topics should therefore be simplified","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","9."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","A top-down approach makes sense, especially for companies that have structured their risk management in this way in order to exploit synergies","ESRS1","ESRS 1  - 3.1 Materiality of information as a general filter for reported information","AR 5"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","45. (b)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The Appendix C should be deleted as it rather adds complexity to the topic and might require additional documentation effort as part of the audit procedures.","ESRS1","ESRS 1  - 3.3 Double materiality assessment","AR 9"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Providing a lit of references in the sustainability statement should be sufficient. No additional cross-referencing should be needed from other source documents to the sustainability statement. Deletion of requirement.","ESRS1","ESRS 1  - 9.3 Incorporation by reference","118. (a)"]
["Excels","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","This is a better term, perceived to be less demanding, as is commented also by EFRAG.","ESRS1","ESRS 1  - 3.3 Double materiality assessment","29."]
["Excels","Sustainability Makers","Business association (other than association of financial institution)","Italy",null,null,"I agree","Flexibility in methodology: We support the option to adopt either a top-down or bottom-up approach, allowing alignment with companies’ internal decision-making and governance structures.","ESRS1","Simplification of the Double Materiality Assessment ('DMA') ","1."]
["Excels","Sustainability Makers","Business association (other than association of financial institution)","Italy",null,null,"I agree","Proportionality and qualitative assessment: We agree that quantitative data or scoring should not always be required, and that qualitative analysis may be sufficient where metrics are difficult to obtain or less appropriate.","ESRS1","Simplification of the Double Materiality Assessment ('DMA') ","1."]
["Excels","Sustainability Makers","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","Consistency and comparability: While we support flexibility, we are concerned that without stronger guiding criteria, companies may apply the DMA too differently, creating risks of inconsistency and arbitrariness. Minimum documentation requirements and clearer rules are needed to mitigate this.","ESRS1","Simplification of the Double Materiality Assessment ('DMA') ","1."]
["Excels","Sustainability Makers","Business association (other than association of financial institution)","Italy",null,null,"I agree","Support for mandatory disclosure reflecting transversal relevance across organizations; promotion of consistency and comparability of sustainability information; contribution to ESRS objectives by driving measurable improvements; encouragement of prompt and effective implementation.","ESRS1","Transformation of six datapoints from “may” to “shall”","3."]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I agree","There is a typo \"The undertaking shall make every dt to ensure…\" ","ESRS1","ESRS 1  - 7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","101."]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Could you precise the last sentance of this paragraph ? ","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","36."]
["Excels","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","Considering Paragraph 46, and the top-down approach as referred to in AR 17, please clarify in which circumstances Paragraph 46 would apply.","ESRS1","ESRS 1  - 3.3 Double materiality assessment","24."]
["Excels","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","When the use of quantitative information required is not specified. While it is welcome that the materiality assessment process can be adapted to individual circumstances, the inclusion of examples in the MIG could provide greater clarity as to when quantification is appropriate and when it is not. ","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","AR 19"]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We propose the following rewording: \"The sustainability statement shall include general information in accordance with [Draft] Amended ESRS 2 and, when necessary, on an entity-specific basis\", removing the term \"material\".\nThe application of DMA to all datapoints of ESRS 2 would be hard to apply considering ESRS 2 sets out general disclosure requirements that apply across sustainability topics and defines the undertakings’ reporting process for the ultimate identification of material information to be disclosed. ","ESRS1","ESRS 1  - 3.6. Determining the information to be reported in accordance with ESRS 2 and topical standards","49."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We propose re-integrating from NMIG for ESRS 1 the \"NMIG 5 for para. 51 (Group and subsidiary level) \" in the main standard as a new Application Requirement to ESRS 1 para 51.","ESRS1","ESRS 1  - 3.7 Level of aggregation, disaggregation and group reporting","51."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We propose re-integrating from NMIG for ESRS 1 the \"NMIG 8 for para. 82 (Impracticability to adjust comparative data) \" in the main standard as a new Application Requirement to ESRS 1 para 82.","ESRS1","ESRS 1  - 7.1 Presenting comparative information","82."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","It appears that ESRS 1 paragraph 87 is intended to provide a complete list of the areas where the concept of undue cost or effort can be applied. ESRS 1 paragraph 87, however, does not include ‘anticipated financial effects’, although application of undue cost or effort to ‘anticipated financial effects’ is specifically mentioned in ESRS 2 AR 15. We recommend EFRAG update ESRS 1 para 87 to include ‘anticipated financial effects’.","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","87."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","To aid simplification, we consider that the provision should be replaced with a requirement to draft the dislcosure in accordance with the new GDRs.  Move the last sentence of the DR into NMIG. The blending of \"may\" and \"shall\" in this DR is slightly awkward wording in that it merges a compulsory action with voluntary outcome and risks becoming a compliance exercise. ","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","11."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","AR 1 for para. 11 is redundant. So, delete it in its entirety. This information is sufficiently covered in ESRS 1, qualitative characteristics of information, and in ESRS 2, reporting areas. ","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","AR 1"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","The following is the second part of our response to question 12 in part two of our response:\n\nMembers have the following specific concerns about the new guidance:  \n\n1.       Definitional Ambiguity: The framework fails to provide clear criteria for distinguishing “significant ongoing actions” from standard business compliance practices which are consistent with regulation. The framework also fails to clarify the distinction between positive and negative impacts. This ambiguity will lead to inconsistent application across companies and industries, undermining the comparability objective that EFRAG seeks to achieve. Additionally, the supportable evidence requirements introduce definitional ambiguity and increase the reporting disclosure burden while the disclosure of expected effects of remediation actions for potential negative impacts remains highly speculative. It may also lead to long exchanges with auditors. ","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","The changes made provide helpful clarification that a quantitative scoring is not required in all cases.","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","AR 19"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","We support the changes made as they allow different definitions for time horizons so that they can be consistent with internal processes and provide better information.","ESRS1","ESRS 1  - 6.2 Time horizon: definition of short-, medium- and long-term for reporting purposes","79."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","We support the changes as they allow for the inclusion of additional information when needed for specific users, e.g., ratings agencies. ","ESRS1","ESRS 1  - 8.2 Presentation of additional information included in the sustainability statement","108."]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","\"Where the impact is deemed material based on this assessment, the undertaking shall disclose the remediation actions undertaken and their expected or actual outcomes.  \" The wording indicates a disclosure requirement of remediation actions on level of each material impact. Deletion or rephrasing should be considered.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","\"[…] if the undertaking needs to maintain significant ongoing mitigation and/or prevention actions\". It is unclear how \"significant ongoing mitigation actions\" should be interpreted. Further clarification is needed.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","35."]
["Excels","Leaseurope","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Leaseurope welcomes this clarification.  \nWe consider the definition of 'leased asset' should be provided, for example is this based on IFRS 16, and if so it is based on the IFRS 16 lease definition before or after any voluntary use of exemptions (short-term assets, low value assets)?  \nWe suggest it should include all leases under IFRS 16 for IFRS users, regardless of whether the preparer has opted to make any voluntary use of exemptions. \nWe shall be pleased to provide a suggested definition.","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","70."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I agree","The definition of stakeholders looks clearer","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 10"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is positive that the assessment of undue cost or effort depends on the company's circumstances. However, a definition of \"undue cost or effort\" is needed","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","89."]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","Para. 40 seems to introduce some form of unnecessary guidance rather a disclosure requirement, considering in particular indent c). It should be deleted.","ESRS1","ESRS 1  - 3.3.2 Financial materiality assessment","40."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I disagree","In its current form, this new or amended paragraph would require significant effort and resources, if not impossible, to assess and provide evidence on variations (or lack of variations) for these factors to determine level of aggregation / disaggregation for large, global undertakings. Nokia proposes to amend the wording significantly, either by bringing back the existing requirements or completely removing this paragraph with reference to variations.","ESRS1","ESRS 1  - 3.6. Determining the information to be reported in accordance with ESRS 2 and topical standards","51."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I disagree","The concept of “reasonable and supportable evidence / information” is not clear and should be removed. Estimates should not be required when no sufficient information is available to compute robust estimates.","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","87."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I agree","These reliefs are important and should be extended to full reliefs (not only partial reliefs).","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","91."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially disagree \nNon-financial users should be limited to business partners, trade unions, social partners and NGO’s representing interest common to society","ESRS1","ESRS 1  - Objective","4."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially disagree\nThe text is an explanation of the term \"general purpose” and should therefore be moved to definitions. ","ESRS1","ESRS 1  - 3.1 Materiality of information as a general filter for reported information","AR 3"]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially agree\nGuidance is needed as to what ‘evidence’ can encompass, i.e. on the level of certainty, when assessing severity levels and likelihoods of impacts, and the magnitude and likelihood of risks and opportunities. Also necessary to explain the reason for using different wording in ESRS 1, paragraphs 45b and 47, i.e. reasonable and supportable evidence/information. ","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","45. (b)"]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially disagree\nRisks and opportunities associated with leased assets should reflect the contractual terms, i.e. the extent to which financial effects can or will be transferred from the lessor (asset owner) to the lessee. The agreed lease payment may be fixed, only adjusted by inflation, or driven by market price of similar assets, which in combination with a short lease term or cancellation rights, can influence the extent to which financial effects, related to impacts from the leased asset, will be transferred to the lessee. \nSpecifically – and as an exemption to the general requirements – it should be possible for the entities to apply the definitions in the GHG-protocol when reporting on GHG according to E1. ","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","70."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I agree","While we agree with the transitional provision whereby comparable information is not required for the first year of preparation of the sustainability statement, we suggest to add – or make it clear – that this also apply in the first year of adopting the amended ESRS standards if/where the amended standard change definitions or disclosure requirements compared to those set by the standards in Set 1. ","ESRS1","ESRS 1  - 10.2 Transitional provision related to Section 7.1 Presenting comparative information","126."]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","If Appendix C is not deleted: Definition of \"significant ongoing mitigation and/or prevention actions\" could cause challenging discussions. In practice, in most cases would we expect any actions to be above this threshold and therefore not to be considered in the materiality assessment, if not clearly inconsequental? We believe that in some cases the treatment of the scenarios in the appendix C are inconsistent with our understanding of the ESRS 1 paragraph 34 and 35.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","35."]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","We suggest the following change in AR 10 to para. 33 (in bold):\n\nCommon categories of affected stakeholders are may include: employees and/or workers' representatives (if applicable), suppliers, consumers or end-users, affected communities and persons in vulnerable situations. ","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 10"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","Considering long-term employee benefit fund, in most cases, employees own shares in the fund and there is nothing on the undertaking's balance sheet. Moreover, the undertaking does not choose the fund investments. Therefore, those assets should not be considered as business relationship of the undertaking.\nRegarding accounting practices, in cases when undertaking holds the fund's shares (in its balance sheet), these assets should classified as non controlled investments (IFRS 9 for example) and those assets will be considered as part of the value chain.","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","71."]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","The paragraph erronously refers back to itself","ESRS1","ESRS 1  - 10.1 Transitional provision related to Chapter 5 Value chain","124."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","par 15 includes explanation regarding the term \"shall consider\" (which is included in AR). DRSC considers this term still too vague as to sufficiently clarify what preparers are asked to do; therefore DRSC has a preference for deletion of this term ","ESRS1","ESRS 1  - 1. ESRS Standards, reporting areas and drafting conventions ","15."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\n\"par 10 of this standard\" \n- is there a reference needed to ESRS 2? ","ESRS1","ESRS 1  - 3.2 Interaction between topics to be reported and material impacts, risks and opportunities","23."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","„Where the impact is deemed material based on this assessment, the undertaking shall disclose the remediation actions undertaken and their expected outcomes.” This new wording indicates a disclosure requirement on the level of each material impact which would lead to a significant increase in the reporting obligations. Deletion or re-phrasing of the sentence should be considered to ensure that the general section on the methodology of the IRO assessment does not directly contain datapoints for disclosure.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I agree","[refers to para 45 et seq] general agreement to the clarification of the concept of focusing the DMA; avoiding an unnecessary level of detail and easing the use of (non-primary) information / \"undue cost or effort\" as a relief to gathering information","ESRS1","ESRS 1  - 3.5 Practical considerations in determining the material impacts, risks and opportunities and their associated topics to be reported","45. (a)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL, par 51 in connection with AR 23 for par 51\npar 51 lists \"locations, water basin, site, asset… \" as though they are all different aspects to consider; in AR 23 the term \"by location\" is specfified as \"by location - such as by site, water basin or local ecosystem\", as though if you differentiate by location, it can be one of the following - if that is the understanding it seems not necessary to include \"location\" in the list in par 51. ","ESRS1","ESRS 1  - 3.7 Level of aggregation, disaggregation and group reporting","51."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL \nThe DRSC considers it important to state that own operations \"usually\" include the assets and liabilities, income and expense of the parent undertaking and its subsidiaries. However, the structure and wording of ESRS 1 ch. 5.1. in connection with ch. 5.3 could imply that the exceptions listed in ch. 5.3 are the only exceptions to \"own operations\". \n\nFor the DRSC it is important to clarify that \"usually\" (in par 59) can refer to other circumstances beyond those addressed in ch. 5.3 (par. 70 and 71). ","ESRS1","ESRS 1  - 5. Reporting undertaking and value chain","59."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","Generally support that estimates are permitted, but this paragraph 62 contradicts ESRS 1 par. 122 (transitional provision related to Chapter 5 Value chain) which limits the relief to the first 3 years. Clarify that the general provision in par 62 applies. ","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","62."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nThroughout ch. 5 the term \"reporting boundary\" is used several times. However, it is not yet included in the Glossary. Furthermore, there is a need to very clearly state that \"reporting boundary\" includes own operations and the VC. At some times the wording could imply that the reporting boundary is limited to own operations. \n\nNote: Annex II Glossary includes a reference to reporting boundaries only in reference to the GHG emissions; it should generally be defined. ","ESRS1","ESRS 1  - 5.4 Relief for acquisitions and disposals","72."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","Which \"that period\" is meant here? Reporting period or preceding period? ","ESRS1","ESRS 1  - 7.6 Changes in the preparation or presentation of sustainability information","94."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I agree","Agree with differentiation between internal references (within Sustainability Statement) and incorporation by reference (to outside information)","ESRS1","ESRS 1  - 8.3 Options in presenting information across parts of the sustainability statement","AR 37"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nshould read \"para 122 and 123\" (not \"123 and 124\"); ","ESRS1","ESRS 1  - 10. Transitional provisions","124."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","We welcome the proposed reliefs regarding the double materiality assessment. However, the requirement to report potential impacts subject to “significant ongoing mitigation or prevention efforts” in its current form leaves interpretive uncertainty that may lead to disproportionate complexity in application as well as difficulties in audit contexts. Given that alignment with auditors on materiality assessments has been a key implementation challenge, the ESRS simplifications should explicitly address this issue to achieve meaningful burden reduction.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","35."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","The choice between a top-down and bottom-up approach to MA should not be subject to additional burden such as the requirement that “is expected to lead to the same outcome as the bottom-up approach”. This requirement may prompt auditors to request validation of this assumption, potentially undermining the intended simplification and therefore it should be deleted","ESRS1","ESRS 1  - 3.3.2 Financial materiality assessment","AR 17"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I disagree"," We suggest deleting this datapoint to reduce complexity and unnecessary reporting burden. ","ESRS1","ESRS 1  - 3.7 Level of aggregation, disaggregation and group reporting","53."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Table of Content: Appendix C should be before Appendix B since \"assessing impacts\" are part of DMA and thus more related to App. A.","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","7."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","A common framework/benchmark for \"significant\" actions is missing and very specific for each company and sector. We do not want EFRAG or other reporting bodies to define \"significant\". This should remain as a term that the company can identify based on their experience and business. The way of operationalization is unclear. e.g. a mitigation measure that equals to current  legal requirements would lead to an on-going reporting about this specific impact while a company fufills all legal requirements that are stipulated to avoid this negative impact. ","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","35."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The general goal of this new requirements will increase the faithful presentation and comparable information reported by different companies. However, it is not clear why to report on \"significant events\" in relation to the \"Subsidiary's or business's exposure to material IROs\". In our opinion, significant events should only be considered in case that they might the overall evaluation of material IROs on group level. We would recommend to further review this requirement.","ESRS1","ESRS 1  - 5.3 Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain","73."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","\nPlease add \"opportunities\" after \"[…] of risks […]\" -> \"[…] materiality assessment of risks and opportunities.\"","ESRS1","ESRS 1  - 3.2 Interaction between topics to be reported and material impacts, risks and opportunities","AR 16"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Would a policy be considered to be a continuous action (hence impact needs to be reported in year after, if all other things are ceteris paribus), or could an effective policy leads to a reduction in a risk and therefore becoming non-material in the year after (e.g. effective health & safety policies)?","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","AR 12"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Issues with level of aggregation/disaggregation required not being principles-based, potentially leading to obscured information - Undertakings should present aggregated information in the first instance and disaggregate by exception when needed; Remove “such as” examples (e.g., water basins) from para 51; Remove AR22. Make AR23 (NEW requirement) a “may consider” (voluntary) rather than a “shall consider” (mandatory) requirement; Revise AR25 to include “an inappropriate level of aggregated or disaggregated information” and “to understand the undertaking’s material impacts”.","ESRS1","3.7 Level of aggregation, disaggregation and group reporting","51-52, AR22-23"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Time intervals should be fully aligned with the IFRS S1 and S2 as this will enable greater comparability longer term","ESRS1","ESRS 1  - 6.2 Time horizon: definition of short-, medium- and long-term for reporting purposes","77."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","The revised ESRS clarify that the standards are intended to support a fair presentation framework, rather than serving merely as a compliance checklist as sometimes interpreted in practice. This shift encourages companies to focus on materiality and relevance in their disclosures, potentially reducing the reporting burden by allowing more judgment and flexibility. However, it may also slightly increase the burden due to the need for other assessments and justifications.  A related potential risk is that voluntary or previously mandatory datapoints now moved to the NMIG (non mandatory implementatin guidance) and the extent they would need to be considered and justified under a fair presentation framework, including evidencing towards (external) assurance providers.\n\nDespite this, we agree with the explicit amendment toward a fair presentation framework, as it better aligns with the principles of materiality and relevance in sustainability reporting. This approach supports more meaningful disclosures and allows companies to tailor reporting to their specific context, rather than following a rigid checklist.","ESRS1","ESRS 1  - 2. Fair presentation and qualitative characteristics of information","16."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","There are a number of metrics that change due to revision of ESRS definition and calculation and will not be 100% comparable to prior period reporting. It is unclear how EFRAG suggest address these transitional changes with comparative information in prior periods based on the delegated ESRS. Guidance is needed for reporters under the existing ESRS when new or revised parameters are introduced through the revised ESRS. This guidance should clarify that any new or amended datapoints resulting from the revision may be omitted for comparative years. ","ESRS1","ESRS 1  - 10. Transitional provisions","126."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","High Priority. Some drafting elements on data collection remain confusing:\n§62 states that direct information from value chain may be used by undertakings to conduct their DMA where §65 states that DMA may be conducted without direct information from value chain.  §65 states that an undertaking may need to obtain additional information from VC actors when materiality is uncertain. This seems inconsistent with earlier provisions allowing undertakings to rely on estimates. \nClarify the general principle in the main body (not only in the AR28): VC information is required only for identifying material IRO (DMA), not for reporting on metrics. This identification of impacts in the VC is important to support initiatives led by the undertaking (PAT) to reduce the impacts of the products and services along the lifecycle, not for reporting purposes. It should be made clear in the main body that VC data is not required for standardised metrics, except for Scope 3 GHGemissions. As currently drafted, §62 refers to undertakings reporting metrics that include value chain information, while AR28 specifies that standardised metrics do not cover the value chain – creating a potential inconsistency. However, it could be explained that entity-specific metrics (not standardised) may require value chain data.","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","62."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Nuance the principle about direct data collection from value chain counterparts in light of the possibility of using estimates (e.g., §65 states that the undertaking may need to seek additional information from value chain actors when materiality is unclear, whereas earlier paragraphs allow the use of estimates based on practical considerations, this may appear inconsistent)","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","65."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","Regarding (b), we have the same suggestion as shared for ESRS 1 – 3 above, so as to replace it with the following wording:  “include material information related to the reporting areas of (i) governance, strategy, impact, risk and opportunity management, as well as related (ii) policies, actions, targets and metrics related to material impacts, risks and opportunities (see [Draft] Amended ESRS 2).”","ESRS1","ESRS 1  - 1. ESRS Standards, reporting areas and drafting conventions ","AR 1"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","This paragraph could be misinterpreted as suggesting that the limitation on requesting information from other companies, as defined by EU law and regulation, implies that the related value chain information does not need to be reported. It is important to clarify that, despite the limits on information requests, the obligation to report value chain information still exists. Companies should pursue alternative methods, such as estimation, to fulfil their reporting requirements.\n\nIn addition, it is unclear to which specific laws and regulation is referred to with the text “the relevant EU law and regulation”. We would propose to specify the EU law and regulation in the glossary. ","ESRS1","ESRS 1  - 5.2 Inclusion of value chain information","63."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I disagree","We recommend EFRAG to remove §92. The concept of joint operations is GAAP specific and this relief will introduce some differences in reporting boundaries which will be complex for users to apprehend and compare. Furthermore, this relief paragraph relies on the notion of operational control, which is not clearly defined in ESRS and would require further guidance.","ESRS1","ESRS 1  - 7.4 Reliefs for metrics","92."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Why linkage to ESRS 1.21 instead of including the definition of materiality of information as core element of a faithful presentation under ESRS 1.19?","ESRS1","ESRS 1  - 1.1 ESRS standards, reporting areas and entity-specific disclosures","19."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","ESRS 1.AR 26 in reference to ESRS 1 3.7 may result in a high number of new datapoints depending on its interpretation by auditors. EFRAG should clearly state that the disaggregation of data is voluntary (“may…”) or delete the AR completely. Furthermore, this disaggregation does not provide any added value for the users of the information; instead, it leads to information overload and unjustified burdens for the disclosing company (information may not be available or only with high effort).","ESRS1","ESRS 1  - 3.7 Level of aggregation, disaggregation and group reporting","51."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","ESRS 1.51 stipulated different level for aggregation and \"other appropriate level\". The segment approach (which is based on a management approach under IFRS) could be highly relevant category for aggregation and should be added as an explicit category.","ESRS1","ESRS 1  - 3.7 Level of aggregation, disaggregation and group reporting","51."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Appreciate the clarity on needing to also review and reference the Application Requirements when determining disclosure requirements and format. ","ESRS1","ESRS 1  - 1.2 Drafting conventions","15."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I agree"," Appreciate the attempt at interoperability and connection with IFRS and financial materiality definitions. ","ESRS1","ESRS 1  - 3.3.2 Financial materiality assessment","37."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," - Tying the level of aggregration/disaggregation to level at which \"significant\" variation arises is problematic given that \"significant\" is undefined. Consequently, it would be better to require aggregation or disaggregation to the extent necessary ensure the fair presentation of the reported information consistent with the requirements of paragraph 19 of ESRS 1. This change would simplify the process given that \"fair presentation\" is the over-arching requirement in any event.","ESRS1","ESRS 1  - 3.7 Level of aggregation, disaggregation and group reporting","51."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," In relation to the activity covered by this clause (d), the term \"reasonable and supportable,\" particularly \"supportable,\" needs to be clarified as it could be interpreted as requiring a level of validation or the implementation of governance and control processes (see, e.g., https://kpmg.com/xx/en/our-insights/ifrg/2024/issb-reasonable-supportable-information.html) that would defeat the term's intended purpose of providing relief to undertakings in situations where the available data is imperfect (see IFRS's Sustainability Reporting Standards FAQs). Since this clause relates to the inclusion of information in the sustainability statement, \"reasonable and supportable information\" in this context should mean that the information is relevant and satisfies the fair presentation and qualitative characteristics of information requirements specified elsewhere in this ESRS. Such an approach is consistent with the acknowledgement in Section 7.2 of ESRS 1 that disclosed information is subject to the application of judgement, as well as measurement and outcome uncertainty.","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","87. (d)"]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Not mentioning any time limit for the update of the conclusions of the materiality assessment gives companies more flexibility","ESRS1","ESRS 1  - 3.3 Double materiality assessment","29."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Contradictive messages in Pt 34 and 35. This will lead to multiple interpretations and will not be practicable. ","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I agree","The option for companies to cross-reference the financial statements when reporting on monetary amounts is positive","ESRS1","ESRS 1  - 9.2 Direct/indirect connectivity with financial statements and consistency of assumptions","114."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Please refer to comment above - to be aligned with proposed changes to para 98 ESRS 1, i.e. to include trade secrets. \n\n\"If the undertaking omits classified information, sensitive information or a specific piece of information corresponding to intellectual property, know-how or the results of innovation which constitutes trade secrets as defined in Article 2, point (1), of Directive (EU) 2016/943, it shall comply with the DR in question by disclosing all other required information.\"","ESRS1","ESRS 1  - 7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","100."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","\"Where the impact is deemed material based on this assessment, the undertaking shall disclose the remediation actions undertaken and their expected or actual outcomes.  \" The wording indicates a disclosure requirement of remediation actions on level of each material impact. Deletion or rephrasing should be considered.","ESRS1","ESRS 1  - 3.3.1 Impact materiality assessment","34."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Reasonable and supportable information is subject to the interpretation of auditors. A clear definition is missing otherwise it undermines the level playing field and will be applied unevenly.","ESRS1","ESRS 1  - 7.3 Use of reasonable and supportable information that is available without undue cost or effort 18","88."]
["Excels","ASD","","",null,null,"I disagree","Board's gender diversity ratio should be calculated as percentage of female members over total board members, instead of average ratio of female to male board members.","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","AR 2."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","There is a need to clarify the object of decision-making procedures - it's currently to vague and could potentially imply any decision-making in the company. \nSuggested wording: \"a description of the decision-making procedures related to the process through which the undertaking identifies impacts, risks, opportunities, and the related topic and assesses their materiality, as the basis for determining the disclosures to be made in its sustainability statement; and\"","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","26. (g)"]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I disagree","A boolean DP (whether) will complicate the structure of a generic GDR-P. Suggestion: transform the instruction on how to disclose into an AR for paragraph 34, and create a separate datapoint 9 in G1-1 to disclose whether such an overarching human rights policy exists or not. Suggested wording: AR for paragraph 34:  If the undertaking has an overarching human rights policy committing to implement the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises, it shall disclose the information according to the provision defined in paragraph 34. The human rights policy shall specify which groups of affected stakeholders are covered (for example, own workforce and workers in the value chain being distinct from consumers and endusers).\n\nAnd change AR 30. for para. 35 to AR 30. for para. 34","ESRS2","ESRS 2 - General for policies - GDR-P","35."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","Suggestion: add \"where applicable,\" to potentially exclude qualitative targets that will be fullfilled by carrying out actions (see comment above on 43b).\n\nSuggested wording: \"where applicable, the methodologies, significant assumptions used to define targets, whether the target is required by law, the selected scenarios on which it is based, the key data sources and the level compatibility with national, EU or international policy goals\"","ESRS2","ESRS 2 - General for targets - GDR-T","43. (f)"]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","DP 40 specifies that \"the undertaking shall disclose the metrics … in relation to material impacts, risks and opportunities\". The aggregation level should reflect this. See comment for ESRS 1-22 for further rationale.\n\nSuggested wording:  \"(i.e.  aggregated at groups of negative impacts, positive impacts, risks or opportunities)\"","ESRS2","ESRS 2 - General for targets - GDR-T","38."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Redundant: Usually the annual corporate governance (management) report has this information. More flexibility should be granted depending on the legal form and the associated company structure","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","9. (c)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Check redundancy with remuneration report obligations under the Shareholders Right Directive.","ESRS2","ESRS 2 - GOV-2 - Integration of sustainability-related performance in incentive schemes","11. (c)"]
["Excels","Atenor","Preparer (non-financial preparing a sustainability report)","Belgium",null,null,"I partially agree and partially disagree","E2.IRO‑1 §11(a), AR 1‑8 – Methods & tools to identify pollution impacts/risks/opportunities\nAllow incorporation by reference to existing site selection/screening methodologies and risk tools documented for regulatory permits (IED) or Taxonomy DNSH. \nIt cuts duplication; leverages audited/regulated files; keeps ESRS narrative focused.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","11. (a)"]
["Excels","Atenor","Preparer (non-financial preparing a sustainability report)","Belgium",null,null,"I partially agree and partially disagree","Issue : scope should follow financial statements; going beyond is hard to operationalise.\nProposal : Keep financial‑control perimeter as default; where a different perimeter is used, require a short reconciliation note (why, direction, magnitude) and explicit cross‑reference to the affected topical disclosures.\nAllow a one‑row “options used” table (phasing, omissions, confidentiality, events after reporting date) rather than narrative.\nDraft wording: “Where the sustainability statement reporting boundary differs from the consolidated financial statements, provide a concise explanation and reconciliation; present ESRS 1/2 in a tabular index rather than narrative.”","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","5. (i)"]
["Excels","Atenor","Preparer (non-financial preparing a sustainability report)","Belgium",null,null,"I partially agree and partially disagree","IRO‑1 — Process to identify and assess material impacts, risks and opportunities (§25–26; AR 19)\nProposal : Name explicitly the Climate Delegated Act’s adaptation workflow (the risk and vulnerability assessment steps for physical climate risk) as an accepted methodology for the identification and assessment of climate‑related physical risks in the undertaking’s own operations and value chain. Incorporate by reference to the underlying assessment document and any resulting adaptation measures.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (a)"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I disagree","Risk management should not be part of GOV-4, as it is already adequately covered and disclosed via financial reporting if environmental risk assessment is integrated in company wide risk assessment. GOV-4 should NOT refer to IRO management (as IRO-1 already requires comprehesive disclosure on IRO management). BDEW supports reduction of scope of GOV-4 to ICS processes for quantitative disclosures for sustainability reporting.","ESRS2","GOV-4 - Risk management and internal controls over sustainability reporting","para 14 / 15"]
["Excels","Society for Corporate Governance","Business association (other than association of financial institution)","United States",null,null,"I disagree","Eliminate the requirements to disclose CapEx and OpEx on actions taken by the reporting entity to manage material sustainability matters. The revised requirements continue to present the challenges for companies previously flagged by the Society. This information may be commercially sensitive and, if disclosed, could compromise a company’s competitive position by providing insights into its cost structures and operational priorities – information that competitors could use unfairly to their advantage. Companies may also face significant challenges when seeking to quantify, produce, and maintain the requested level of financial disclosures, increasing their administrative burden. This detail is also unnecessary for stakeholders to understand a company’s sustainability-related IROs, where the action is already described and the expenditures are not material, and would not provide meaningful insight into the effectiveness of actions taken. These challenges persist even when companies are able to disclose a range, as such detail can still share competitive information and may ultimately be unhelpful to stakeholders (e.g., where the disclosed range is so expansive it provides limited or no sense of scale). In the event EFRAG determines not to eliminate these disclosure requirements, we recommend alternatives in our concurrently submitted comment letter.","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38."]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I partially agree and partially disagree","Suggest turning into datapoint and amend text to highlight that social impacts eg on communities (s3) are also context / location specific","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 22."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I disagree","We acknowledge that the financial effects disclosure requirement has been removed and consolidated under ESRS 2 SBM-3, which addresses financial impacts across all material topics in a cross-cutting manner. This consolidation allows for a more integrated and structured approach to financial risk management.\nHowever, it may reduce the visibility of pollution; water; biodiversity, Use of resources and waste specific financial effects, particularly in sectors with high environmental impacts and risk, and in the same way that have exposure to environmental regulations. While this change may simplify reporting, it limits users’ ability to understand the potential financial risks associated with this environmental topics, such as regulatory liabilities, contamination-related costs, or opportunities linked to sustainable innovation.\nThe absence of this requirement could weaken the connection between sustainability and financial performance, which was one of the core objectives of the ESRS.\nTo preserve relevance and decision-usefulness, it may be helpful to recommend optional environmental specific financial disclosures, especially for high-impact sectors. This would ensure that critical risks and opportunities remain visible within the broader financial reporting framework.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","23."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","With regards to the composition of the administrative, management and supervisory bodies, we deem it important to retain prior mandatory data points on member's experience relevant to sectors, products and geographic locations of undertaking (former paragraph 21 (c)) and how sustainability-related skills and expertise relate to material impacts, risks and opportunities (former paragraph 23 (b)). This is important information for understanding the governance of impacts. Proposed paragraph 9 b does not give information on the current competencies of members but only asks for information about the determination process. These two former data points could be merged and simplified in line with GRI 2-9-c-viii (member's competencies that are relevant to the impacts of the organization). A new AR could clarify that competencies relevant to the impacts of the undertaking include competencies relevant to impacts commonly associated with the undertaking's sectors, products, and geographic locations.","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","9. (a)"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We deem it important to retain prior standalone mandatory data point on key actions taken (along with results) to provide for and cooperate in or support the provision of remedy for those harmed by actual material impacts (former paragraph 68 (d)) within this DR. The inclusion of prevention, mitigation and remediation in paragraph 32(a) is not fully clear with regards to the status of these contents as data points in their own right. We suggest that actions to prevent and mitigate potential negative impacts on one hand, and to remediate actual negative impacts on the other, become standalone mandatory data points within paragraph 37, to ensure this information is not overlooked and can be easily identifiable by users and stakeholders. This would also support alignment with GRI 3-3-d. ","ESRS2","ESRS 2 - General for actions and resources - GDR-A","37. (a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","We urge the removal of the implied mandatory disclosure requirement of all internal performance indicators (KPI) because the datapoint requests \"shall disclose the metrics that it uses to evaluate its performance\". This datapoint should only focus on the mandatory datapoints of the ESRS. The company has more KPI internally that are used for monitoring but these cannot all be made public.","ESRS2","ESRS 2 - General for metrics - GDR-M","40."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Datapoint should be deleted as a list of sectors does not provide any added value for external users (no decision-useful information). As there will be no sector-specific ESRS, details on significant sectors will not be provided by preparers (or only based on other frameworks such as SASB). If no clear provision on the use of a specific sector classification is given, the disclosures will be incomparable even within one industry (no added value for users). If NACE code as classification is used (as suggested by NMIG 5 for SBM-1) a reference to the financial reporting makes no sense as financial reporting is not based on NACE codes. Also EU Taxonomy might not fit properly in that classification.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","AR 7."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","\"significant resources\" should be changed into \"significant financial resources\" as the reminder of the whole par. 38 is about financial resources. EFRAG should think about giving an indication what is meant by \"significant\". The term \"significant resources\" is not defined.","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","\"financial resources\" should be changed into \"significant financial resources\" to align the wording within par. 38. ","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38. (c)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We consider that, instead of requiring references to specific pages or paragraphs, the linkage should be made at the section level of the report. This approach would significantly ease the process for preparers when compiling the content table, as referencing individual pages or paragraphs is highly resource-intensive and time-consuming. Linking at section level would maintain traceability while improving efficiency and usability.","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","AR 25."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Language should be reviewed in order to be clear about that the expertise refers to the whole body has, not the different individuals that compose it.","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","AR 3."]
["Excels","UNICEF","NGO","United States",null,null,"I partially agree and partially disagree","UNICEF welcomes the references to the UNGPs, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines. However, Recital 49 of the CSRD (copied below) included a reference to the UN Convention on the Rights of the Child, as well as other international human rights instruments. Given that children (all persons below the age of 18) account for almost one third of the world’s population, we believe it is important for their rights to be highlighted when referencing international human rights instruments.\n\nRecital 49 of the CSRD: ”The sustainability reporting standards should also specify the information that undertakings should disclose with regard to the human rights, fundamental freedoms, democratic principles and standards established in the International Bill of Human Rights and other core UN human rights conventions, including the UN Convention on the Rights of Persons with Disabilities, the UN Declaration on the Rights of Indigenous Peoples, the UN Convention on the Rights of the Child, the ILO Declaration on Fundamental Principles and Rights at Work, the fundamental conventions of the ILO, the European Convention for the Protection of Human Rights and Fundamental Freedoms, the European Social Charter, and the Charter of Fundamental Rights of the European Union. “","ESRS2","ESRS 2 - General for policies - GDR-P","35."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","As the ESRS do not mandate any behaviour, we invite EFRAG to specify that this DP only applies when a due diligence process is in place.","ESRS2","ESRS 2 - GOV-3 - Statement on due diligence","13."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","We recommend clarifying what level of information is expected in the justification that the undertaking shall provide when it did not deem climate change as material as it could otherwise lead to diverging interpretations. Illustrative wording in the NMIG would be useful.","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28. (b)"]
["Excels","University of Warwick, Coventry, United Kingdom","Academia","United Kingdom",null,null,"I partially agree and partially disagree","It is vitally important that companies report individually on material impacts. Our research has identifed that this is absolutely vital to the credibility of corporate disclosure in due diligence processes. So please delete references to allowing companies to report \"at the appropriate level of aggregation\". We have recently written a 2 page policy brief which makes the case for the importance of this issue in more detail. See https://warwick.ac.uk/fac/soc/law/research/centres/chrp/publications/due_diligence_and_european_sustainability_reporting_standards_10.09.25.pdf","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","AR 23."]
["Excels","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria",null,null,"I partially agree and partially disagree","We recommend to streamline 2.37a and c as both of them refer to the time horizon. This could be moved to 2.37 (before 2.37a starts).","ESRS2","ESRS 2 - General for actions and resources - GDR-A","37."]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Delete as this refers to the \"how\"; the outcome of managing sustainability topics is relevant for stakeholders, not the \"how\"","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","9. (c)"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Delete. Recommendation to report the outcome and not the process; it would be an option to disclose the process in a separate publication (voluntarily)","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","25."]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I disagree","Current financial effects are not necessarily presented \"individually\" in the financial statements. Direct reference is therefore not feasible.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","23. (a)"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I disagree","From our reading of the standard, there are overalps between SBM-1, SBM-3 and IRO-2. All three disclosure requirements include a description of the business model, strategy and decision-making with regards to material sustainability impacts, risks and opportunities:\nSBM-1: \"The undertaking shall disclose the following information about the key elements of its general strategy that relate to or affect material impacts, risks and opportunities\"\nSBM-3: \"The undertaking shall provide a high-level description of the interaction of the material impacts, risks and opportunities, with its business model, value chain, strategy and decision-making\"\nIRO-2: \"concise description of ... imaterial impacts...as well as its material risks and opportunities...and how and where impacts, risks and opportunities are connected to its business model, its own operations and its upstream and downstream value chain.\"\n\nWe recommend to integrate these provisions in SBM-1 and remove the duplications from  SBM-3 and IRO-2. SBM-3 should be focused on current and anticipated financial effects.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","We recommend to include topic-specific application requirements to SBM-3 para. 23 (anticipated financial effects) related for pollution and biodiversity. For pollution, the AR should refer to revenues from products that contain substances of very high concern, OpEx and CapEx related to major incidents and costs from environmental protection and remediation of pollution as aspects that can be reported as actual or anticipated financial effects. There should also be a link to biodiversity and ecosystem- (\"nature-)related financial effects that the undertaking can report here, if material. If it proofs difficult to reinstate these requirements in the AR for ESRS 2, they should at least be included in the non-mandatory guidance.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","23. (b)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend clarifying the “differences” in the reporting boundary from the consolidated financial statements to which the undertaking is required to report upon, that would then correspond to the only acceptable “deviations” from an auditor’s perspective.","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","4."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","We recommend maintaining the information required by § 4 on the reporting boundary and the value chain consideration within the General information section in order to preserve the integrity of DR BP-1. ","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","AR 1."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","Equinor supports simplification in removing IRO-1 sections from the topical standards.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","25."]
["Excels","UGT-ESPAÑA","Trade union","Spain",null,null,"I agree","It is crucial to keep this datapoint in on reporting on stakeholder engagement, particularly for workers' representatives, as this is a requirement in CSRD","ESRS2","ESRS 2 - SBM-2 - Interests and views of stakeholders","20. (c)"]
["Excels","UGT-ESPAÑA","Trade union","Spain",null,null,"I agree","It is crucial to report how workers' representatives views have been taken into account by the undertakings' decision making bodies","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 21."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I disagree","In accordance with the previous point 65f, which has been deleted. We believe that this point should be reinstated, as reports are a source of knowledge and interested parties can find out where these documents are available on the basis of the report. This is the only source of information about where the company informs them about this. ","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","34."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","To be added an additional bullet containing \"Should the undertaking have no policies, actions, metrics, or targets in place relating to these areas, it shall be explicitly stated.\"","ESRS2","ESRS 2 - BP-2 - Specific information if the undertaking uses phasing-in options","7. (e)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","Pls, bear in mind that the term sustainability-related expertise is not directly mentioned on par 9 (b)","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","AR 3."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We would suggest to modify b) by: b) The main results derived from engaging with these stakeholders, specifically in relation to identifying and evaluating  impacts, risks, and opportunities.","ESRS2","ESRS 2 - SBM-2 - Interests and views of stakeholders","20. (b)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We would suggest to exchange \"consultations\" for \"engagement\": whether and how the process includes engagement with….\nThis is streghed in AR 21 for para 26(d), since a mention to \"engagement\" processes is included.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (d)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Prevention, mitigation and remediation are terms linked to negative impacts. Pls include some terms to also covered positive ones.","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","32. (a)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nIf GDR-P is changed to focus on key policies, GDR-A would have to follow suit\nThe use of the term resources is inconsistent within this section. On the one hand there is mentioning of CapEx and OpEx, on the other hand there is mentioning of financial and other resources.\nSuggestion:\nWording should be made consistent. Consider using the term resources in this section and add the definition of resources to the Appendix with acronyms and defined terms.","ESRS2","ESRS 2 - General for actions and resources - GDR-A",""]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nInconsistent wording: use the term negative impacts instead of adverse impacts; in addition, be careful with the use of the term \"risk\" which has a very specific meaning in ESRS; it is also questionable why in this context the adverse/negative impacts are emphasized.\nSuggestion:\nChange wording:\nthe scope of operations and value chain covered, with an indication of whether it focuses on specific activities, business relationships, geographies or other factors that give rise to heightened risk of adverse impacts;","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (b)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Why is this separately called out? If this is a result of Draft Amended ESRS S1 and ESRS S2 should it not be exclusively addressed in these topic-specific standards?","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28. (e)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nThis sentence reads a bit strange in the context of providing information about sustainability governance.\nThe other challenge is that the paragraph refers to several governance bodies and then uses the word “oversee”. While ”oversee” would be appropriate in relation to supervisory bodies, it would not be appropriate in relation to management bodies because they determine strategies and other measures.\nSuggestion:\nChange wording:\nhow the administrative, management and supervisory bodies determine whether ensure that appropriate skills and expertise are available or will be developed to determine respectively oversee strategies and other measures designed to respond to material sustainability-related impacts, risks and opportunities (or groups of them / related topics)","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","9. (b)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nWhy is the term “other measures” used instead of the term “metrics”. Wording should be consistent with other paragraphs.\nSuggestion:\nChange wording:\nInformation on how the undertaking addresses or plans to address its material impacts, risks and opportunities, which interact with its business model or strategy, includes a clear reference to the specific policies, actions, targets and other measures metrics it implemented during the reporting period to manage them, as disclosed in line with the GDRs and the relevant topical standards.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","AR 14"]
["Excels","IMA-Europe ","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Agree with option 2","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","23. (b)"]
["Excels","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","“reportable sector”  same wording as in IFRS 8 “segments” would be helpful to avoid misinterpretation","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17."]
["Excels","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland",null,null,"I partially agree and partially disagree","ESRS 2 para 26. a and AR 19 mention input parameters. Para 26a distinguishes between input parameters and data sources, but in the AR19, it is mentioned that input parameters may include specific data sources. So there is a bit of overlap between the term input parameter (which includes data sources) and key data sources. ","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (a)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I disagree","This section, transferred from GOV-4, is simplified but fails to explain what due diligence entails. It also lacks a reference to ESRS 1 and presents unclear expectations compared to the current ESRS standards. Paragraph 13 should include a cross-reference to ESRS 1 for clarity and alignment","ESRS2","ESRS 2 - GOV-3 - Statement on due diligence","13."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","The AR should be moved under BP-1","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","AR 1."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The following sentence should be added: \"The undertakings shall consider ESRS 1 point 81 second sentence.","ESRS2","ESRS 2 - General for actions and resources - GDR-A","36."]
["Excels","ESMA","European supervisory authority","France",null,null,"I partially agree and partially disagree","89.\tIRO-1 par. 26 and AR 20: ESMA agrees that the IRO-1 topical disclosures in ESRS Set 1 were overly detailed and caused implementation challenges. Further simplification could be achieved by turning some datapoints into Application Requirements for par. 26 a). This approach could be relevant for par. 26 c) and par. 26 e). In addition, while AR 20 establishes that the disclosures under par. 26 b) to g) specify rather than expand the disclosures outlined in par. 26 a), it does not describe the links between the different datapoints, which would be helpful for undertakings to better understand the disclosure requirements. ESMA welcomes the focus on information that reflects the specificities of the individual undertakings for reporting on the materiality assessment process as included in AR 20.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26."]
["Excels","ESMA","European supervisory authority","France",null,null,"I partially agree and partially disagree","95.\tIn addition, considering the increased flexibilities in grouping of IROs and presentation, ESMA thinks that the IROs should be clearly disclosed as related to one or several ESRS sub-topics, where relevant, or topics or signposted as related to entity-specific disclosures as part of their description. This could be part of the table proposed in AR 25. ESMA would be in favour of this table being a mandatory requirement rather than a voluntary one. See also the responses to questions 13 and 15 on this issue.","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This DR might imply a lot of text without any valuable information by just disclosing that there aren't adopted policies, actions or targets to a certain material topic. ","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","30."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Inconcise. Needs to be includes in the topic-specific Standards and not in ESRS 2 in order to align to the new ambition to reduce the complexion of the ESRS.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 22."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","CHANGE. The current concept of reporting relief based on undue costs and efforts does not lead to any reduction of reporting burden for larger companies. Instead, it should be referred to the financial reporting where significant financial effects are displayed.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","AR 15."]
["Excels","Little Blue Research","Consultant (including software vendor)","United Kingdom",null,null,"I partially agree and partially disagree","Missing dependencies  - this is out of alignment with the TNFD and ISO 14054 Natural Capital Accounting for Organizations (forthcoming). Should be \"The description of its material impacts, dependencies, risks and opportunities shall be provided at the appropriate level of aggregation, either individually or for group(s) of impacts, dependencies, risks and opportunities, or for the related topic(s),\"","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","AR 23."]
["Excels","Little Blue Research","Consultant (including software vendor)","United Kingdom",null,null,"I partially agree and partially disagree","Missing dependencies  - this is out of alignment with the TNFD and ISO 14054 Natural Capital Accounting for Organizations (forthcoming).Should be \"If the undertaking categorises its material impacts, dependencies, risks and opportunities in accordance with a set of management priorities, reflecting their relevance to the undertaking’s strategy and business model, the way disclosures are structured and presented may reflect this approach .\"","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","31."]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I partially agree and partially disagree","Companies should also be required to disclose whether they have assessed their own involvement (i.e. whether they cause, contribute, or are linked to) to their material impacts and if so, what the conclusion of that assessment has been.\n\n","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28. (a)"]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I disagree","From our reading of the standard, there are overalps between SBM-1, SBM-3 and IRO-2. All three disclosure requirements include a description of the business model, strategy and decision-making with regards to material sustainability impacts, risks and opportunities:\nSBM-1: \"The undertaking shall disclose the following information about the key elements of its general strategy that relate to or affect material impacts, risks and opportunities\"\nSBM-3: \"The undertaking shall provide a high-level description of the interaction of the material impacts, risks and opportunities, with its business model, value chain, strategy and decision-making\"\nIRO-2: \"concise description of ... imaterial impacts...as well as its material risks and opportunities...and how and where impacts, risks and opportunities are connected to its business model, its own operations and its upstream and downstream value chain.\"\n\nWe recommend to integrate these provisions in SBM-1 and remove the duplications from  SBM-3 and IRO-2. SBM-3 should be focused on current and anticipated financial effects.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","Add an application requirement to link CapEx for key actions to the CapEx plans under the EU Taxonomy (Art. 8, DA) which increases interoperability between ESRS and the Taxonomy:\n\"If applicable, the undertaking shall relate its CapEx amounts to the , the CapEx plan required by Commission Delegated Regulation (EU) 2021/2178.\"","ESRS2","ESRS 2 - General for actions and resources - GDR-A","AR 35."]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","Similarly to the option to present IROs together with policies, information on how actions contribute to meeting the goals set out by policies should be allowed to be presented jointly. ","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","37. (b)"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","We do not agree to add 1.5°C reference in the requirement (better approach can be keeping a reference to the 2050 objective), as it relies on large-scale deployment of negative emissions technologies (NETs) like carbon capture and storage (CCS) or availability of the biofuels, which are not yet proven/commercially viable at scale.","E1","E1-1 - Transition plan for climate change mitigation","13."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The information requested is sensitive for an organization as it clearly shows the potential vulnerabilities/possible competitive angles on the market. ","E1","E1-2 - Climate-related risks and scenario analysis","AR 7"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","(a) Information on \"anticipated long-term CapEx and/or OpEx ranges\" are very difficult to gather and not always relevant for all the topic. As such, this information should be voluntary.\n(b) The information requested is sensitive for an organization as it clearly shows the potential vulnerabilities/possible competitive angles on the market.","E1","E1-5 - Actions and resources in relation to climate change","24. (c)"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Not clear how the following can be evaluated \"fails to convery a fair presentation of the emissions…\". This is very subjective and open for wide interpretation therefore not aiding in clarity of application.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","19."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","(a) The information requested is sensitive for an organization as it clearly shows the potential vulnerabilities/possible competitive angles on the market.\n(b) Please refer to question 19 of the General Section","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","The reporting requirement makes the stakeholder engagement indirectly binding. This should be avoided, as the CSRD does not usually define implementation obligations but reporting obligations. The option of reporting that no dtructured engagement takes place should be introduced.","ESRS2","ESRS 2 - SBM-2 - Interests and views of stakeholders","20."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","To be deleted as this is a \"may\" datapoint and might broaden the scope of resources to be disclosed and might lead to discussions with auditors.","ESRS2","","AR 36."]
["Excels","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","It is a complex process to calculate current and future resources, so consider removing this requirement. Getting this information does not provide too much value to stakeholders.","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38."]
["Excels","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","agree to leave out topics omitted","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","27."]
["Excels","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland",null,null,"I agree","It is crucial to report how workers' representatives views have been taken into account by the undertakings' decision making bodies","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 21."]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","It was already unclear and it remains like this. When asking for the % by gender and other aspects of diversity that we take into accout  : what is requested exactly the % by gender on the board only ? ","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","9. (a)"]
["Excels","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","For some metrics the information required by topical ESRS is not specifically defined or relevant for financial institutions (e.g., banks). In those situations, we already considered those metrics that are used to evaluate our performance. Please clarify how the disclosure of these metrics on an entity-specific basis should be dealt with in combination with those metrics on a topical ESRS basis, in the situation that you cannot disclose upon the topical ESRS metrics. In other words, shouldn’t you also assess (via your information materiality) if the topical ESRS metrics are relevant considering the evaluation of its performance. If not relevant, you should disclose those entity-specific metrics that are used to evaluate your performance but you shouldn’t or cannot disclose the topical ESRS metrics. Based on the amended paragraph it is not clear if solely disclosing entity-specific metrics, in case the topical ESRS metrics are not relevant, is possible. ESRS 1 Chapter 7.4 Relief of metrics, more specifically Paragraph 90, and ESRS 1 Appendix B: Qualitative characteristics of information, more specifically the Section on relevance, does provide some guidance. Please clarify. ","ESRS2","ESRS 2 - General for metrics - GDR-M","40."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","We suggest deleting \"where applicable\" as as we believe it is essential to disclose such information if exists. We therefore suggest to restore previous paragraph as currently exists in ESRS Set 1 as per Delegated Act 2023 ","ESRS2","ESRS 2 - General for targets - GDR-T","43. (d)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The term reporting boundary is associated with the value chain, not with the consolidation scope. \n\nChange the wording to: \n\n\"… and in case the consolidated scope is different from the one adopted in the consolidated financial statements, a description of and the reasons for these circumstances\"","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","4."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","In our view this paragraph should be moved ahead of other paragraphs in ESRS SBM-1 to streamline the logic flow of the DR.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","18."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","We propose the deletion of this AR because it does not serve the simplification purposes of the ESRS revision; undertakings can describe groups of products and/or services offered, significant markets and/or customer groups served, and the sustainability-related goals related to them with a more strategic perspective, complying with qualitative characteristics of information.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","AR 10."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Paragraph 31 should be changed from a Disclosure Requirement to an Application Requirement.","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","31."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","Paragraphs 41 (b) and (c) are not necessary because (b) is already implicitly covered in ESRS 2. Paragraph 41 (a) and (c) is already covered in ESRS 1.","ESRS2","ESRS 2 - General for metrics - GDR-M","41."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","We believe these disclosures are burdensome and it is not practicable to meet all GDR-T and E1-6 disclosures for long-term (usually 2050) Net Zero Commitments or Targets. These are typically managed through a focus on the relevant interim targets along the pathway to Net Zero. Items expected by GDR-T and E1-6 will not be available for target setting 25 years out, resulting in non-decision useful information that is unlikely to meet the Quality of information requirements of ESRS 1. Undertakings that have made long-term Net Zero commitments should be able to limit disclosure to their interim targets which corresponds to how this is managed. Can EFRAG clarify this either in the standards or the NMIG since the Glossary definition of \"target\" will still pick up firms’ 2050 net zero commitments.","ESRS2","ESRS 2 - General for targets - GDR-T","42."]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Changing the significant financial resources allocated for implementing action plans to \"key actions\" broadens the scope of the requirements and therefore goes against the simplification and reduction aim of EFRAG. It should be changes back to the original wording or completely taken out.","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Explaining how a company prioritises risks can be burdensome since prioritisation is a case-by-case process","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","While this is important to understand if something is material or not, it should be clear whether the LEAP approach is mandatory or voluntary","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 22."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","Nokia welcomes the introduction of the relief “undue cost or effort” and focus on IFRS interoperability (ESRS 1, paragraph 60). However, it is not really clear what “undue cost or effort” means, how it should be computed and how deep in the supply chain the assessment should run. We call for the introduction of practical boundaries for this concept and how to calculate and demonstrate that required efforts and costs have been met to exercise this relief. See also Nokia’s comments regarding “reasonable and supportable” information / evidence in ESRS 1 - 81.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","AR 15."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially agree\nThe reporting requirement assumes a “full process”, while it does not cater for the “update” envisaged in ESRS 1, paragraph 29. We are missing a reflection of the disclosure in its second year and onwards. We recommend it is added that an entity which already have reported on it’s DMA process is only required to update on the process conducted in the FY covered by the annual report. (Similar to how you would normally provide strategy updates in the midst of a strategy cycle). This is to ensure that the entity is not repeating information already disclosure in the previous year and which might not have been repeated in the current year, if the underlying assumptions for the DMA have not changed and therefore an updated DMA and associated processes have not been conducted. In these circumstances there should be text which specifies, what the current FY processes have been.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (a)"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","Generally the Objective section fails to describe the actual general objective of ESRS 2, but rather address specific concepts. It is important for first time readers of the standards to understand the relationship between ESRS 1 and ESRS 2, which should be captured in the Objective sections.\n\nFor example, this paragraph makes it sound as if the only purpose of ESRS 2 is to describe the GDRs, which is not the case. Instead it should be made clearer how there is a link between the principles set out in ESRS 1 and the disclosures in ESRS 2, making it clear ESRS 2 sets out the actual disclosure requirements following from the general principles and requirements.","ESRS2","ESRS 2 - Objective","1."]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","We suggest to bring clarity about how to consider the term 'active' and its application to the financial sector.\nFor example is 'active' defined by treference to significantly financing or allocating funding to that sector ? If yes, how to consider 'significantly finance'?","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","AR 8."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nAgree with new data point to disclose statement on the application of ESRS 1 requirements incl. an indication of the use of reliefs provided in ESRS 1; \n\nHowever, while we appreciate the streamlined 'comply or explain' approach to only state deviations from the ESRS 1 General requirements provisions, we would find it useful to provide that information in the relevant context and to not list all the details in the first section. \n\nWe recommend reconsidering the detailed requirements, e.g. requirement in par 5(d), as partial scoping (e.g. extrapolation for own operations or selective inclusion of entities for upstream KPIs) has already been common practice and did not require explicit disclosure. Mandating such disclosure may introduce unnecessary complexity and reporting burden without significantly improving transparency. We suggest clarifying whether these detailed requirement are intended to change current practice or simply formalise existing flexibility.","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","5."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I agree","new relief for acquisitions and disposals (as laid out in ESRS 1.72-73, see also ESRS 1)","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","5. (k)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","[relates to 17(a)(ii)] There is currently no definition of \"banned products\" (i.e. products and services banned in certain markets). There is a need for clarification on which products are to be considered \"banned\". Are banned products and services those that were introduced into a certain market and afterwards banned? Does this require a specific decision by e.g. a national legislator or regulator? What is to be reported if the undertaking has withdrawn the products / services before a decision was made? Also, some products / services of undertakings are not intended to be sold in a certain market, e.g. b/c there is not demand for them in those markets. [continues in box below]","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17. (a)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nis this reference to the general principles in ESRS 1 a valuable AR? (\"shall use reasonable and supportable information available to it at the reporting date without undue cost or effort\") - these principles are relevant for all disclosures and do not seem to add information for the preparer (undue cost or effort relief is explained in ESRS 1)","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","AR 15."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nQuestionable whether this requirement can useful be addressed in a disclosure. It seems to rather result in boilerplate language only. \n \"the approach used to consider impacts and dependencies in identifying and assessing its risks \nand opportunities\" (but this is not a new requirement) \n\nGenerally, the separate aspects of the list of par 26 seem to relate to each other; difficult to separatly identify each item? \n\nIt could therefore be helpful to introduce these aspects by: \"this disclosure shall include...\" (rather than list as if separate disclosures on each are needed); this impression is also supported by the need to further explain any differences in AR 20 ). ","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (e)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nIt seems questionable whether this AR is needed. AR 28 merely repeats general underlying principles from ESRS 1, e.g.  reporting for the reporting period / no boilerplate. It does not seem necessary to repeat these requirements that are generally applicable to all disclosures. It will raise the question how these requirements are different for General PATM compared to other disclosures. Suggestion to delete. ","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","AR 28."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","The level of reference for information on current and future financial resources allocated or expected has changed from \"action plans\" (in the DA) to \"key actions\" in the ESRSamend. The log of amendment states that par 38 has been \"adjusted to link financial resources to key actions\". This seems to entail a different, likely more detailed link between financial resources and key actions than before (key actions likely being part of \"actions plans\"). It should be clarified that there is no change intended with this amendment to the disclosure requirement. ","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I disagree","We do not agree with the requirement to combine a mandatory statement that the general requirements of ESRS 1 have been applied with an indication of whether and which of the provisions listed in ESRS 2, paragraph 5 have been applied. This results in meaningless boilerplate text and redundant disclosures. Compliance with ESRS 1 is self-evident, and any use of its provisions is already accompanied by mandatory disclosures under ESRS 1 itself. For example, where an undertaking applies the relief for metrics with a partial scope (ESRS 1, paragraph 91) or restates information due to error correction (ESRS 1, paragraphs 95-97), sufficient transparency is ensured by contextual explanation, disclosure of the limited scope, and correction of prior figures. Requiring additional statements under ESRS 2, paragraph 5 only duplicates this information without providing added value for readers. We therefore recommend deleting the requirement or at least limiting it to cases where paragraph 5 could genuinely add clarity and avoid duplication. ","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","5."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","ESRS S2, S3 and S4 are not classified as metric-containing standards (ESRS 2 AR 37). However, the phrase “disclose these” implies quantitative disclosure, creating confusion about whether these should be treated as metrics and how they fit into the overall metrics and targets framework.","ESRS2","ESRS 2 - General for metrics - GDR-M","AR 37."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","The AR should be moved to BP-1 to follow the structure that each AR sits next to the respective DR is covers.","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","AR 1."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","We are strongly against the inlcusion of any disclosure on anticipated financial affects. By year-end, risks have either materialized and led to financial effects or have not. If they have materialized we are of the opinion that disclosures of material financial effects are covered by respective IFRS standards. Therefore, both options should be deleted. we recommend aligning the sustainability reporting requirements with existing risk reporting standards, which should serve as the basis for such disclosures for all risks and not only ESG-risks. In our opinion, sustainability reporting should not override or extend these principles through financial disclosure requirements in the sustainability statement. \nWe therefore recommend that this disclosure requirement should be removed entirely or made explicitly optional.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","23. (b)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The DMA process does not require the inclusion of site-level / location-based analysis according to ESRS 1. Why is this AR required? Should it clarify that this is additional information on the DMA in case site-level / location has been considered? We suggest to clarify the role of this AR and the link to the disclosures on the DMA and the DMA prcess requirements themselves.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 22."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The wording should be aligned throughout the whole par. 38 including the connected AR. The wording \"significant financial resources\" should be used to align the wording within par. 38. \"Resource allocation\" and \"resources\" should be replaced accordingly. It should also be clarified that a disclosing a monetary range for the planned allocation of significant financial resources over the whole time period is sufficient.","ESRS2","ESRS 2 - General for actions and resources - GDR-A","AR 35."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Should this read 'not delegated' (and not: 'delegated')?","ESRS2","ESRS 2 - GOV-1 - The role of the administrative, management and supervisory bodies in relation to sustainability","9. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","For the reader, it might be helpful if a specific sector classification system should be used by all preparers. That drives uniform reporting and less research for readers when they need to look up a sector classification system to understand the DR.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17. (b)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","The AR is supposed to clarify the concept 'key stakeholders' however does not really address what is considered key ('Key stakeholders refer to key categories of affected stakeholders'). If the deliberate intention is to keep this generic, then agreed.","ESRS2","ESRS 2 - SBM-2 - Interests and views of stakeholders","AR 11."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","More appropriate to keep as it was: “a description of a decision-making process and the related internal control procedures”, the entire document is mentioning high level processes and does not make sense to change the wording here.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","26. (g)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Issue with labeling impacts as negative or positive when this distinction may not be clear and/or an accurate representation of complex topics for all impacts. In addition, the NEW requirement to specify how these impacts affect or are likely to affect people or the environment may lead to inaccurate, incomplete or misleading information about potential impacts – Revise the requirement to specify that undertakings are not required to label impacts as positive or negative and remove the phrase “including how they affect or are likely to affect people or the environment” from the requirement.","ESRS2","IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28(a)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","We do not support the revised requirement to disclose a breakdown of activities per sector and their connection to IROs. This level of detail is already sufficiently covered through disclosures on the business model and strategy, where material impacts, risks, and opportunities (IROs) are explained in context. Additionally, ESRS 2 already requires companies to indicate where in the value chain IROs occur. Further granularity is also available through EU Taxonomy disclosures, financial statement segment reporting, and the broader annual report, which together provide a comprehensive view of the undertaking’s activities. Including this breakdown in the ESRS adds reporting burden without clear added value and risks duplicating existing disclosures.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17. (b)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Clarify that ESRS 2 starts from the topic level (strategic entry point), with disclosures on associated material IROs where relevant – not the other way around “this standard refers to disclosing on both the topics to be reported and the material impacts, risks and opportunities”","ESRS2","ESRS 2 - Objective","2."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Delete the disclosure requirement GOV-3 \"Statement on due diligence\"; instead include a placeholder in ESRS 1 addressing the articulation between the ESRS and due diligence","ESRS2","ESRS 2 - GOV-3 - Statement on due diligence","13."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Delete the data point on changes related to its material IROs compared to the previous reporting period, and merge it with the existing data point (§26g) on “description of the decision-making procedures, including significant changes compared to prior reporting period”","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28. (c)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","We urge the removal of the implied mandatory disclosure requirement of all internal performance indicators (KPI) because the datapoint requests \"shall disclose the metrics that it uses to evaluate its performance\". This datapoint should only focus on the mandatory datapoints of the ESRS. The company has more KPI internally that are used for monitoring but these cannot all be made public.","ESRS2","ESRS 2 - General for metrics - GDR-M","40."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","We consider that ESRS 2 BP-1 §5(h) should be modified, as the exact scope of omission covered by this requirement is unclear. It could be understood as relating to:\n-\t(a)“classified and sensitive information” covered by ESRS 1.98 and\n-\t(b) information about impending developments or matters in the course of negotiation covered by ESRS 1.AR 35 –as indicated literally by the drafting of the datapoint; or relating also to\n-\t(c) information pertaining to intellectual property, know-how or the results of innovation covered by ESRS 1 §99 – as indicated by the reference into brackets in this datapoint, mentioning ESRS 1.99 and 101. \nWe would expect a requirement to disclose whether information was omitted relating to situations (b) and (c) in line with the current requirements under ESRS Set 1.\nThe requirement to disclose the omission of “classified and sensitive information” (situation (a)) as suggested by the ED goes beyond ESRS Set 1 which does not require companies to explicitly confirm omission of “classified and sensitive information”. This is  to avoid disclosing the existence of such information defined by EU laws, and inadvertently compromising confidentiality or security. ","ESRS2","ESRS 2 - BP-1 - Basis for the preparation of the sustainability statement","5. (h)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","Para 20 and AR11 for Para 20 only refer to engagement with ‘affected stakeholders’. Previously, in Set 1, this requirement referred to the general definition of stakeholders (including ‘primary users of information’). \nWe ask EFRAG to clarify if this reduction in scope was intended.\nIt may be relevant in some sectors (in particular banking, fintech etc.) to engage / disclose information on views and interests of users such as investors. ","ESRS2","ESRS 2 - SBM-2 - Interests and views of stakeholders","20."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","We welcome this additional flexibility provided by EFRAG with regards to the presentation of the description of material IROs.","ESRS2","ESRS 2 - General Disclosure Requirements for Policies, Actions, Metrics and Targets","AR 29."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Datapoint should be deleted as a list of sectors does not provide any added value for external users (no decision-useful information). As there will be no sector-specific ESRS, details on significant sectors will not be provided by preparers (or only based on other frameworks such as SASB). If no clear provision on the use of a specific sector classification is given, the disclosures will be incomparable even within one industry (no added value for users). If NACE code as classification is used (as suggested by NMIG 5 for SBM-1) a reference to the financial reporting makes no sense as financial reporting is not based on NACE codes. Also EU Taxonomy might not fit properly in that classification.","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","AR 7."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We are strongly against the inlcudion of any disclosure on anticipated financial affects. Both options should be deleted.","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","AR 17."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","\"financial resources\" should be changed into \"significant financial resources\" to align the wording within par. 38. ","ESRS2","ESRS 2 - General for actions and resources - GDR-A","38. (b)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","ED 2025 §6-7 replacing 2023 BP-2 §6-17.  Overall compliance effort does not materially change through the proposal to migrate obligations to BP-1 and retain multiple bullet point confirmations.  Only removes optionality for narrative and limit scope exclusively for undertakings with > 750 employees.","ESRS2","ESRS 2 - BP-2 - Specific information if the undertaking uses phasing-in options","6."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," ED §11 vs 2023 §29.  Improved to only if applicable and limits data points.  Data points reduced from five to three: removes (i) identification of specific benchmarks in remuneration policy and (ii) level at which schemes are approved.  Still requires monetised % of variable pay, which is commercially sensitive information.","ESRS2","ESRS 2 - GOV-2 - Integration of sustainability-related performance in incentive schemes","11."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," ED §28(d)-(f) vs 2023 §56-57.   Change does not simplify; the new labour-risk disclosure introduces additional supply-chain mapping.  While the proposal removes granular cross-referencing, it adds a mandaotry labour-risk table resulting in an overall net effect of neutral to heavier for global supply-chains.","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Information that is sector-specific should be managed on an individual basis","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","AR 7."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Same as above","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","AR 8."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Qualitative information should be mandatory instead of quantitative information as collection of quantitative information is subject to a high degree of uncertainty. Data for a precise calculation is not available. ","ESRS2","ESRS 2 - SBM -3 - Interaction of material impacts and opportunities with strategy and business model, and financial effects","23. (b)"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The application requirement should be deleted as this could lead to unnecessary discussions with auditors on the level of detail to be included. If the ESRS  requirements are clearly described, this AR should be redundant.","ESRS2","ESRS 2 - IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 20."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Deletion of \"concise\" as this is subject to interpretation.","ESRS2","ESRS 2 - IRO-2 - Material impacts, risks and opportunities and Disclosure Requirements included in the sustainability statement","28. (a)"]
["Excels","UNESPA (Spanish Association of Insurers and Reinsurers)","Association of financial institutions","Spain",null,null,"I disagree","GDR-P §34 (previously MDR-P §65) requires disclosing the material impacts, risks or opportunities to which the policy relates. Since IROs are already disclosed in IRO-2 §28 (a), it is redundant to also disclose them in GDR-P.","ESRS2","ESRS 2 - General for policies - GDR-P","34."]
["Excels","ASD","","",null,null,"I agree","We welcome EFRAG proposed change for Disclosure Requirement E1-8 – Gross Scopes 1, 2, 3 and Total GHG emissions","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","8."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","A specific narrative content will complicate the structure of a generic GDR-A. Suggestion: Create an AR to specify content (without a specific DP): \"In addition to [Draft] Amended ESRS 2 GDR-A, when disclosing current and planned actions, the undertaking shall:  present its key climate change mitigation actions by decarbonisation lever;\"","E1","E1-5 - Actions and resources in relation to climate change","24. (a)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Disproportionate costs; Concerns about usefulness (While providing information on what type of energy is purchased is important, the level of granularity and the effort to collect the information related to each type of contractual instruments (e.g. RECs) does not seem to be proportionate considering the usefulness for external stakeholders).","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","24. (b)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Disproportionate costs; Lack of a common methodology; Concerns on data reliability.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (f)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Disproportionate costs; Concerns on data reliability; Data not currently available.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (d)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The wording \"shall provide its climate resilience at the reporting date\" creates confusion: 1) it is not clear as to what it refers to, \"process\" or \"outcome\"; 2) if \"process\" is meant: we don't see the relevance of this information; 3) if \"outcome\" is meant: it seems conceptually understandable, but such purely reporting date-specific statement only makes sense for individual locations or individual products/services/markets. When considering location, product and service portfolios a date-specific assessment is not feasible. Furthermore, a historical analysis (which is what a reporting date analysis is) is questionable in the context of a strategically oriented disclosure such as E1-3. This will result in extensive discussions between preparers and auditors.","E1","E1-3 - Resilience in relation to climate change","AR 9"]
["Excels","Atenor","Preparer (non-financial preparing a sustainability report)","Belgium",null,null,"I partially agree and partially disagree","ESRS E1 §14\nIssue: No explicit permission to cross-reference Taxonomy evidence.\nProposed simplification: Add permission to cross-reference.\nProposed text: See clause 16(c) below.\nWhy it helps: Aligns ESRS with existing Taxonomy documentation practices.","E1","E1-1 - Transition plan for climate change mitigation","14."]
["Excels","Atenor","Preparer (non-financial preparing a sustainability report)","Belgium",null,null,"I partially agree and partially disagree","E1‑5 Actions and resources in relation to climate change (§23–24)\nIssue : \nThe non‑mandatory guidance already shows how to connect actions and resources to Article 8 and EU Taxonomy activities, but because it is guidance, reporting is uneven, and assurance is harder.\n\nProposal : \nallow direct linkage to structure actions and resources by EU Taxonomy activity; Cross‑reference Article 8 KPIs (and any CapEx Plan);\n\nSuggested wording (add to §24(c)):\n“Where relevant, structure actions and resources by EU Taxonomy activity and cross‑reference to Article 8 KPIs.\"\n\nWhy it helps: Improves consistency and assurance.","E1","E1-5 - Actions and resources in relation to climate change","23."]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I agree","\"shall provide its climate resilience at the reporting date” (1) is not clear as to what it refers to, \"process\" or \"outcome\" (2) if \"process\" is meant, we fail to see the relevance of this information, (3) if outcome: It seems conceptually understandable, but such a purely reporting date-specific statement only makes sense for individual locations or individual products/services/markets. When considering location, product, and service portfolios, however, a date-specific assessment is not feasible. Furthermore, a historical analysis (which is what a reporting date analysis is) is questionable in the context of a strategically oriented disclosure such as E1-3. Practitioners in particular fear potential conflicts with auditors in this regard.","E1","E1-3 Resilience in relation to climate change","AR 9"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I agree","Practitioners report pointless discussions with auditors about whether a disclosure in millions is possible here. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","32"]
["Excels","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","In the context of AR 19, the wording is not comprehensible. If, under paragraph (DR) 32 (on E1-8), I apply operational control IN ADDITION to the financial control approach, as AR 19 applies, it is possible to implement Scope 1 and 2 targets related to climate change ONLY according to the operational control approach. From our point of view, this argues in favor of continuing to allow both approaches, financial and operational control, to be equivalent with regard to Paragraph 32, and not have financial control as the default option. ","E1","E1-6 - Targets related to climate change","AR 15"]
["Excels","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The wording presupposes that GHG emissions must first be presented according to financial control (even if this does not represent a fair presentation) and only then may they be presented ADDITIONALLY according to operational control.\n\nThe wording and the default to financial control has a significant impact on our previous reporting scope for data collection on our greenhouse gas emissions and changes our “consolidation boundary” as a company. In our opinion, the default to financial control does not result in a meaningful application and explicitly contradicts the GHG Protocol. The GHG Protocol allows both the operational control and financial control approaches to be used to limit the reporting scope of the organization. In our opinion, the argument presented (see Basis for Conclusion, e.g., 143 a) and 145) that this is in line with the GHG Protocol is therefore not valid. We therefore request the option to use the operational control approach as the default option for reporting GHG emissions. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 18"]
["Excels","TomTom NV","Preparer (non-financial preparing a sustainability report)","Netherlands",null,null,"I disagree","The amendment to the DR, which now requires reporting by all sectors rather than just High Climate Impact Sectors related to energy consumption from fossil fuels, undermines the goal of simplifying the ESRS. For non-HCIS, this change imposes a significant reporting burden and demands considerable effort to collect relevant data, ultimately providing little value in return.","E1","E1-7 - Energy consumption and mix","29."]
["Excels","Vereniging Milieudefensie","NGO","Netherlands",null,null,"I partially agree and partially disagree","Disclosure of significant CapEx amounts related to coal, oil and gas-related economic activities must be maintained.\n\nAn adapted version of this requirement must be added for financial institutions, requiring that they:\n- disclose financial services to coal, oil and gas-related activities, disaggregated by type of fossil fuel and  by type of service\n- disclose financial services to companies involved in new coal, oil and gas-related activities specifically, disaggregated by type of fossil fuel and by type of service \n- disclose financial services to renewable versus non-renewable energy, disdaggregated by energy source\n- disclose their energy supply ratio","E1","E1-1 - Transition plan for climate change mitigation","14. (b)"]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","The thematic reorganisation of DR E1-3, focusing exclusively on climate resilience analysis and transferring risk-related elements to DR E1-2  is a welcome change. It allows for a clearer focus on resilience disclosures and aligns the requirement with IFRS S2, promoting interoperability between the two reporting standards. Additionally, it reinforces the strategic importance of resilience, especially for sectors highly exposed to climate risks. DR E1-3 thus takes on a central role as a tool to assess the robustness of the business model against adverse climate scenarios.","E1","E1-3 - Resilience in relation to climate change","20."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I partially agree and partially disagree","DR E1-8 continues to focus on the quantification and characterisation of GHG emissions, while introducing important clarifications:\n• The inclusion of biogenic emissions represents progress in line with international standards.\n• The harmonisation of the operational threshold with ESRS 1 improves consistency and interoperability, especially with IFRS S2.\nHowever, the removal of the requirement to report emissions intensity (relative to net revenue) may reduce comparability between companies, particularly across sectors with different operational scales.\nTo maintain comparability, it could be useful to recommend voluntary disclosure of emissions intensity, especially for high-impact sectors. This would support more meaningful benchmarking and sectoral analysis.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","31."]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","-          We do not see the relevance of a distinct disclosure of biogenic emissions as required by paragraph 33","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","33."]
["Excels","European Biogas Association","Other - please specify (required)","Belgium",null,null,"I partially agree and partially disagree","While this AR fully allows the use of the EU ETS Methodology for sectors under or not under the EU ETS, a clearer recognition of regulated market-based instruments such as RED-compliant Proofs of Sustainability, should be worded, to ensure clarity for reporters whatever the way that the EU ETS MRR is implemented in Member States.\n\nSuggested amendment: \"For activities reporting under the EU Emissions Trading Scheme (ETS), the undertaking shall report on Scope 1 emissions following the EU ETS methodology. The EU ETS methodology may also be applied to activities in geographies and sectors that are not covered by the EU ETS, where regulated market instruments based on certification and third-party auditing may be used.\"","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 22"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","AR 16 establishes the need for separate targets for Scope 1+2 and Scope 3, consistent with the requirements of GRI 102. We therefore suggest revising paragraph 26 to ensure that this distinction is made explicit.","E1","E1-6 - Targets related to climate change","26."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I agree","The disaggregation of energy consumption by fossil sources was previously only required for organizations in high climate impact sectors. The current requirement is more aligned with GRI 103 and provides more transparency on energy consumption from fossil fuels.","E1","E1-7 - Energy consumption and mix","29."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We suggest including in the table separate reporting of biogenic CO2 emissions, in line with E1-8 33.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 27"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","GRI 102 recommends but does not require an explanation of whether the removal projects are from nature-based or technological sinks. We suggest moving this to the NMIG for simplification purposes and for alignment with GRI.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","36. (c)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Letter (c) it is incoherent the boundary of the numerator and the denominator: the numerator as per letter a is referred to \"operational sites\" while the denominator seems to be required on financial boundary. This data is irrelevant.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 23"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The requirement on the qualitative assessment on locked-in GHG emissions from key assets and products is unclear and not comparable.  The recording of locked-in GHG emissions is time-consuming and generates little added value. A qualitative assessment is not comparable between companies. It is unclear what counts as key assets and products. \nProposal: Deletion of the paragraph, as it offers no added value and generates a lot of effort. \n ","E1","E1-1 - Transition plan for climate change mitigation","14. (c)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Additional requirements that mean increased effort in carrying out the resilience analysis and providing evidence. Consideration of the points listed offers no added value for external stakeholders like investors. ","E1","E1-3 - Resilience in relation to climate change","AR 10"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We welcome the revisions regarding the table to report on emissions and the flexibilities it allows in presenting the information.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 27"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","We believe that estimating the monetary and percentage impact on net revenue from transitional risks before considering mitigation and adaptation measures is highly challenging. Given the high uncertainty surrounding future policy changes, technological developments, and market shifts, it is more meaningful to incorporate measures into the assessment. Disclosing risks without accounting for planned actions may be misleading and fail to provide an accurate picture of the true risk exposure.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Such estimates are highly challenging because opportunities related to the transition are difficult to quantify accurately. Additionally, due to competitive reasons, we would prefer not to disclose such figures, as they could reveal strategic information and be misinterpreted. ","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","42."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","We do not understand why the metric \"Percentage of Scope 1 GHG emissions from regulated emission trading schemes\" is being retained. We recommend removing the addendum to simplify reporting.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","32. (a)"]
["Excels","REWE Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Challenges with understanding and calculation methodology of potential locked-in GHG emissions. This is not applicable to all companies, only for those that have emissions-intensive assets with a long lifetime. Make this DP voluntary and/or conditional, as it only applies to certain sectors, and specific assets. ","E1","E1-1 - Transition plan for climate change mitigation","14. (c)"]
["Excels","REWE Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Further guidance required, as it remains unclear whether mitigation matters are to be included or not - the question is, if measures at current state should be taken into account or not. This is still unclear","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (d)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","In this comment we are referring to former AR 28 on emission reduction factors, which is deleted in the current proposal. We believe the precisions brought by former AR 28 are useful to support the calculation of a 1.5°C-aligned reference target value.","E1","E1-6 - Targets related to climate change","26."]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I agree","We agree with the financial control approach.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","8."]
["Excels","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria",null,null,"I partially agree and partially disagree","We would like to raise concerns regarding the interpretation of AR 15 for E1.26 (GHG emissions reduction targets compatible with 1.5°C). AR 15 refers to companies applying the operational control boundary under E1-8. Yet the revised E1-8 requires the financial control boundary as the default, with operational control disclosure only where needed to avoid unfair presentation of Scope 1 and Scope 2 emissions. Generally, target setting only makes sense on an operational control basis. Setting a target for a leased asset (for Scopes 1 and 2) does not make sense if it is not possible to influence emissions in this area. We therefore recommend that the operational control approach also be permitted for E1-8.","E1","E1-6 - Targets related to climate change","AR 15"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","The value of this information depends on the sector","E1","E1-1 - Transition plan for climate change mitigation","14. (d)"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Biogenic emissions should not count from our perspective, current reporting can lead to double counting and misinterpretations, also not aligned with reporting under EU ETS","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 21 (e)"]
["Excels","European Renewable Gas Registry","Other - please specify (required)","Belgium",null,null,"I disagree","Suggested amendment: (d) (AR 46(g) amended) prioritise direct measurement of Scope 3 GHG emissions and, where this is not possible, further prioritise their inputs and assumptions based on the characteristics of the data (e.g. data from specific activities within the entity’s upstream and downstream value chain, timely data that faithfully represents the jurisdiction of, and the technology used for, the upstream and downstream value chain activity and its GHG emissions, and data that has been verified); to this end, regulated market instruments based on certification and third-party auditing may be used.\n\nComment: \"In the EU, Proofs of Sustainability are a market instrument legally rooted in the RED and issued within regulated mass-balance systems. The certification framework is supported by national or voluntary schemes recognised by the European Commission, requiring third-party audits, standardised GHG emission accounting, and traceability from feedstock to end-use. Production plants are certified. On this basis, producers can issue PoS that accompany biomethane consignments through the gas infrastructure, where the EU gas grid is legally treated as a single logistical facility. This robust architecture enables companies purchasing certified biomethane (with PoS) to demonstrate measurable and verifiable emissions reductions—even if the physical gas is delivered via shared infrastructure.\"","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 25"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I disagree","In regard to §26 c) companies  remind that the European Commission committed to define by end of 2025 the meaning of “compatibility between companies’target and 1.5°C targets”. Until such a definition is published, no obligations are legitimate on this issue.","E1","E1-6 - Targets related to climate change","6."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","Change title  to \"Policies related to climate change mitigation, adaptation and energy\" to put more emphasis on the sub-topics of the standard. Change \"climate policies\" to \"policies on climate change mitigation, adaptation and energy\"","E1","E1-4 - Policies related to climate change","22."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","The Commission should rapidly clarify what is expected from an undertaking, when reporting on the compatibility of its transition plan with the goal to limit global warming to 1.5°C.","E1","E1-1 - Transition plan for climate change mitigation","14. (a)"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","We note that this paragraph is not fully clear. \n1) E1-2 does not specifiy of which types of scenario anaylsis are possible. E1-2 is the disclosure requirement covering provisions for scenario analysis. Therefore, the distinction between qualitative and quantitative analysis should be introduced already in E1-2. \n2) independently from the scenario analysis being quantiative, semi-quantitative or qualitative, the underatking should consider the interplay between E1-2, E1-3 and E1-11. We suggest to EFRAG to revisit these provisions and better align the requirements.","E1","E1-3 - Resilience in relation to climate change","AR 8"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I disagree","The proposed amendment of ESRS E1-10 on internal carbon pricing schemes suggests that an undertaking shall report “the price per metric tonne of GHG emissions” (para. 38 (b)). Often companies apply different internal carbon prices for different purposes. Hence, it is unclear which price is to be reported. EFRAG should specify that transparency is expected for the average carbon price in each pricing scheme the undertaking applies.","E1","E1-10 - Internal carbon pricing","38. (b)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","The revised E1-3 improves alignment with IFRS S2 but removes explicit mention of certain aspects that helped delimit scope and increase clarity in Set 1.\nWe recommend that EFRAG reintroduces description of boundaries or exclusions in resilience analysis from ex-AR6.","E1","E1-3 - Resilience in relation to climate change","AR 9"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","We acknowledge the streamlining of E1-11 and its improved interoperability with IFRS S2. However, despite the reduction in datapoints, the current disclosure remains too granular and insufficiently prioritised compared to ISSB; we recommend allowing aggregation with clear guidance, while retaining quantitative reporting only for key metrics to ensure decision-usefulness and comparability.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","40."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I partially agree and partially disagree","Par. 28 and AR 17 c). This DR/AR specify that energy consumption shall be disclosed in MWh. Propose to make it clearer that if more appropriate, energy consumption can also be reported in kWh, GWh, TWh, etc. ","E1","E1-7 - Energy consumption and mix","28."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I partially agree and partially disagree","Para 29 includes a requirement to disaggreget its total energy consumption from fossil sources, including (e) consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources. Propose that a requirement to disclose the \"consumption of purchasaed or acquired electricity.... from renewable sources\" and also \"consumption of purchased or acquired electricity.... from nuclear sources\" are also included in E1-7, either direcly in para 28 or specified / made clearer in AR 17.","E1","E1-7 - Energy consumption and mix","29."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I partially agree and partially disagree","Equinor strongly supports opening for the use of current industry reporting boundaries like the GHG protocol when reporting our emissions. However, clarification of the concept of\"fair presentation\"is needed. What constitutes a “fair” view from the perspective of the users of the sustainability statement and ensure interoperability with IFRS Sustainability Disclosure Standards. See also our comments to ESRS 1 and Q25 in part 2.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 19"]
["Excels","Danish National Funding Mechanism","(National) standard setter","Denmark",null,null,"I disagree","We find this datapoint onerous and resulting in overly granular disclosure of little relevance. If not removed, it should be limited to real estate assets exposed to material transitional risks, net of mitigation actions at the reporting date.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (c)"]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I disagree","There is no explanation of the time period covered by the description of progress in implementing the transformation plan.","E1","E1-1 - Transition plan for climate change mitigation","14. (d)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We suggest to include something like \"the undertaking may include this information (progress in implementing the transition plan) while describing the transition plan\"","E1","E1 - Interaction with other ESRS","4."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Please be aware that applying decarbonization levers may not always be suitable in this context. For instance, when the positive impact relates to supporting climate change mitigation through solutions that enable third parties to lower their greenhouse gas emissions, these levers might not be applicable. As such, we recommend either removing this reference or offering additional clarification.","E1","E1-4 - Policies related to climate change","24. (a)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Please see comments above. ","E1","E1-4 - Policies related to climate change","24. (b)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","Point b was deleted because it was too broad in scope, but its purpose was correct. Removing it enables “scenario picking,” which limits comparability and the assessment of the information provided. Considering the phase-in period for valuing anticipated financial effects, it would have been better to keep the requirement to explain “why it believes the range of scenarios used covers its plausible risks and uncertainties,” linked to the disclosure of anticipated financial effects.","E1","E1-1 - Transition plan for climate change mitigation","13."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","This requirement overlaps with the DMA and risks resulting in duplicative reporting without ensuring the intended focus of E1-2 on climate risks and scenarios. The deletion of sub-paragraphs does not contribute to clarity in implementation. More generally, this issue applies to all comparable DRs: the cross-references to SBM3 and IRO-1 do not add value. Such overlaps should therefore be removed, and it should be made clear—through explicit and, where necessary, detailed references within the connected DRs—that double reporting is not required.","E1","E1-2 - Climate-related risks and scenario analysis","16."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","The deletion of intensity metrics removes one of the few KPIs that enable proper benchmarking of companies within industries. Moreover, these metrics can always be calculated by users with the available information, meaning they required zero additional effort from CSRD report preparers and offered no real simplification. Given that CSRD sector standards are not planned for the coming years, removing the KPI instead of integrating it and providing more flexibility in disclosure is not the correct solution.","E1","E1-7 - Energy consumption and mix","30."]
["Excels","Allianz SE","Insurance","Germany",null,null,"I disagree","The DR of \"quantitative short- and medium-term CapEx, and/or OpEx figures, as well as anticipated long-term CapEx and/or OpEx ranges\" goes beyond the old ESRS. It brings stricter requirments and the risk of requiring sensitive information. We therefore suggest to remove the new requirement as it contradicts the intended simplification. It should be reassessed in a future ESRS revision. (The relief on sensitive information will not help as even the fact that the undertaking reports that it has omitted sensitive information might be a problem.)","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","Allianz SE","Insurance","Germany",null,null,"I partially agree and partially disagree","Requirement on \"location of key assets at material physical risks\" results in unnecessarily detailed reporting, as depending on the sector, this could involve a large number of locations in all regions of the world. As an example, logistic sector undertakings have much more sites than heavy industry.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","40. (b)"]
["Excels","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland",null,null,"I partially agree and partially disagree","Paragraph 22 only mentions that anticipated financial effects must be addressed for risks and opportunitites. But the AR also refers to impacts. It is not clear whether the financial effects of impacts must also be addressed, since its part of the AR but not the datapoint 22.","E1","E1-4 - Policies related to climate change","AR 14"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The simplification regarding the exclusion of climate risks from separate disclosure is entirely appropriate, but the transfer of information on how risks are identified to the NMIG is inappropriate. The analysis should continue to include, among other things:  identification of risks over different time horizons,  assessment of the sensitivity and exposure of assets to risks,  determination of the probability, scale, and duration of these risks, development of an analysis based on at least one high-emission climate scenario.\nIt is necessary to have a list of risks, which is the starting point for further analysis.\nConsequence:\n•    the lack of risk list will make it difficult to compare data between entities,\n•    an entity may not have knowledge or awareness of the scale of these risks and thus omit significant risks in its analysis – incorrect risk assessment\n•    lack of consistency with the taxonomy","E1","E1-2 - Climate-related risks and scenario analysis","16."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree"," E1-1- 14 and E1-5-24 should be combined in one DR instead of two DRs asking for the same actions. ","E1","E1-5 - Actions and resources in relation to climate change","24."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","undertakings need to be able to communicate past achievements ","E1","E1-6 - Targets related to climate change","AR 25"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Please see comment to ESRS E1 - 29.","E1","E1-7 - Energy consumption and mix","29. (d)"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","- AR 21 (d): \"any removals,\" should be deleted, please see  comments to ESRS E1 26. (a) and ESRS E1 26. (c).","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 21"]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I partially agree and partially disagree","The compatibility of the undertaking's business model and climate measures and goals should also be examined in relation to the goals of the national climate policy objectives and not only in relation to the EU goals. In this way, transition plans should also take national special circumstances into account, such as the issue of forest carbon sinks in Finland. With such a requirement, the climate transition plan could also be better aligned with the biodiversity transition plan (where an assessment towards national policy is required).","E1","E1-1 - Transition plan for climate change mitigation","13."]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I partially agree and partially disagree","The wording should be clarified: \"...include the [ADD: absolute] achieved\nand expected GHG emission reduction [ADD: by the target year set in E1-6]\"\n","E1","E1-5 - Actions and resources in relation to climate change","24. (b)"]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I partially agree and partially disagree","The requirement should include explicit wordings of the claims that have been used and clear information on what emissions (and how many tonnes) have been offsetted for each claim.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","37."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I agree","Transition plans are essential for report users in the financial sector, but also for public policy and civil society, to understand an undertaking’s contribution to mitigate climate change. The requirement to report a transition plan, based on different essential and supporting elements (or “key features”), should consequently remain a central part of ESRS E1. ","E1","E1-1 - Transition plan for climate change mitigation","13."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","The requirement is lacking a clarification on the time horizons undertakings are expected to consider. We recommend to specify as follows: \"The undertaking shall explain how it has defined short-, medium- and long-term time horizons for the identification of climate-related transition events and how these definitions are linked to the expected lifetime of its assets, strategic planning horizons and capital allocation plans\"","E1","E1-2 - Climate-related risks and scenario analysis","AR 6"]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","The reporting of GHG emissions under proposed amended ESRS E1-8 is based on the GHG Protocol Corporate Standard, Scope 2 Guidance and Scope 3 Standard. These standards do not explicitly define how to account for the non-CO2-climate effects of air traffic (especially NOx emissions and long-lived contrails), which are significant. However, it is common practice to account for these effects through the “radiative forcing index” (RFI). We recommend to EFRAG to include a provision in Application Requirement (AR) 21 that these effects shall be included in the GHG inventory and that RFI used is to be disclosed. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 21"]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","WE note that the text of NMIG 12 for para. 41(d) need to be amended in accordance with E1-8 (delete total GHG emissions)","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (d)"]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","For clarity and readability, it should be possible to include this section in ESRS E1 - 1.  ","E1","E1-6 - Targets related to climate change","AR 14"]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I disagree","Disclosures on anticipated financial effects should be voluntary, at least for the first 5 years after the adoption of amended ESRS. This conviction is supported by evidence provided in the first round of ESRS simplification consultation. Firstly, lack of common methodologies by design hinders comparability and makes this disclosure mundane for the end user, while imposing significant burden on issuers, who have to produce such methodologies, validate them etc. – which is especially valid for wave 1 issuers and groups that need to consolidate data from various markets. There are no sectoral pathways at the EU level that issuers could refer to, and available toolkits relate almost exclusively to the operational aspect of transition planning and climate-related transformation, and not financial valuations. Not all industries are equally exposed to and equally dependent on this transformation. Anticipated financial data eg. on energy sourcing transformation and energy costs are considered sensitive information in many cases. Furthermore, significant anticipated financial events are already included in financial statements.  ","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","39."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Manufacturing and use of microplastics should not be included in this DR in their current form, as this disclosure duplicates obligations already established in Set 1 of ESRS and under Regulation (EU) 2023/2055 (REACH), as well as industry frameworks such as Operation Clean Sweep (OCS). Production is not a pollutant per se and should instead be addressed, if relevant, as a key product in E5-5 Resource outflows. Primary microplastic production and use may also be sensitive and confidential. For example, in the proposal for the Regulation on preventing plastic pellet losses it was explicitly noted that “confidential business information is safeguarded.” Regulation (EU) 2023/2055 already requires mandatory reporting on the quantity of synthetic polymer microparticles released into the environment and introduces a ban on intentionally added microplastics in final products, recognising that manufacturing data is not the relevant focus.","E2","E2-4 - Pollution of air, water and soil","15."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Disclosure Requirement E2-4 on primary microplastic can include the quantity of plastic pellet and/or additional microplastic released that it considers material. The calculation methodology on  plastic pellet release should be consistent with the one used for regulation 2023/2055.  Data on primary microplastic release could be provided as percentage respect produced or used microplastics ","E2","E2-4 - Pollution of air, water and soil","AR 1"]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The text under AR 2 in ESRS E1 is not clear on what still should be disclosed: While this information helps demonstrate the coherence and credibility of the transition plan, there is no expectation that the undertaking disclose all internal information used to manage the plan.","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","AR 18/19 should be merged, allowing for both financial control (consolidation) and/or operational control (consolidation) boundary, as defined in the GHG Protocol","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 19"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","related to AR 5 (c), AR 6 (c): The requirement \"base ist analysis on at least one high-emission climate scenario\" is not appropriate. E1 should refer to \"a scenario based on scientific evidence which reflects the climate risk properly\". The current formulation of the AR indicate behavior obligations in how to conduct the scenario analysis going against ESRS 2 (ED) para. 5. Particularly the mandatory use of geospatial data and detailed methodological requirements related to supply chain lead to unnecessary complexity in the overall requirements. Reformulation needed (previously \"This description shall include its process in relation to [...]\").","E1","E1-2 - Climate-related risks and scenario analysis","AR 5"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The breakdown of GHG targets in Scope 1, 2, 3 should not be required as targets are typically not set in this way. E1 should require presentation of targets as the undertaking's management has set these (management approach).","E1","E1-6 - Targets related to climate change","26."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","\"The assumptions regarding permance\" seems an extension of the DA. As there is no evidence on the relevance of this information it should be deleted.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","35. (c)"]
["Excels","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","Consider deleting this disclosure requirement.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","42."]
["Excels","SBTi","Standard setting initiative","United Kingdom",null,null,"I partially agree and partially disagree","We suggest that the disclosure of a statement on whether the GHG emission reduction targets are science-based and compatible with limiting global warming to 1.5°C.should also include validation date, status (near-term, net-zero) and when requesting for the specific methodology (e.g., SDA, absolute contraction) the provision should reference to the SBTi sectoral decarbonisation approaches in the following way: \"The undertaking shall state which framework and methodology underpin the targets, including whether they are based on a sectoral decarbonisation pathway such as those developed by the Science based targets Initiative and regularly updated on the SBTi website, and the underlying climate and policy scenarios.\" We encourage  to include SBTI reference because without reference to a recognised framework, companies may report targets that are framed differently and not comparable. Referencing SBTi approaches ensures users (investors, policymakers, regulators) can benchmark across companies.","E1","E1-6 - Targets related to climate change","26. (b)"]
["Excels","SBTi","Standard setting initiative","United Kingdom",null,null,"I disagree","On amendment of paragraph 61 (GHG neutrality claims using carbon credits): SBTi supports the clarification and streamlining of the text.However, we recommend including clear definitions of “GHG neutrality claims” and “carbon credits,” aligned with recognised frameworks (e.g., ISO, ICVCM, SBTi). This helps avoid greenwashing and misinterpretation. ","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","34."]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I disagree","AR 8 to §20 added a requirement: \"shall consider the implications of the combined assessments performed according to DRs E1-2\". This new obligation is excessive and should be suppressed.","E1","E1-3 - Resilience in relation to climate change","3."]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I disagree","§24 c) adds a “shall” disclosure to indicate different CapEx and OpEx for 3 horizons: short term, medium term and long term; this is too prescriptive, gives rise to uncertainty and may be considered as misleading for the markets. Therefore, global information can be provided but only for significant amounts of CapEx/OpEx and without obligations of time horizon.","E1","E1-5 - Actions and resources in relation to climate change","5."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I disagree","AR2 asks for consolidated narrative linking targets, actions, CapEx/OpEx and governance, but allows that internal management information need not all be disclosed. The threshold of what constitutes “key features” vs. confidential internal modelling is ambiguous. Companies will struggle to balance transparency with commercially sensitive detail; auditors will struggle to know whether withheld details are material. ","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Why is the KPI target only in absolute value ? Indeed, the objective is set up in % and this % doesn't change. Whereas the absolute value might change depending on different cases partly described in AR13a.","E1","E1-6 - Targets related to climate change","26. (a)"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","It would be useful to add a definition of storage and removal projects","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","35."]
["Excels","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden",null,null,"I disagree","I strongly disagree. It is necessary to use intensity-figures to enable sectoral comparability and benchmarking, both financial and physical denominators (Former para E1-6 para 53, not really new AR 19). I believe that it is necessary that all companies operating in high climate impact sectors have to disclose energy intensity and climate intensity. I also think that the addition of physical intensity based figures (production volumes or sold products) should be disclosed. Even though it may not enable comparability between sectors, it can enable comparability within sectors and most importantly, be really useful for internal analysis and business strategy,as well as meet the objective of ESRS of fair presentation.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 19"]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We recommend re-integrating the existing para. 60 of ESRS Set 1 about in the case of Net Zero targets in addition to the gross GHG emission reduction targets. We believe that if an organisation has a Net Zero target, it has this type of information available.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","36."]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","We view the removal of the addition concerning high climate impact sectors as a positive step.","E1","E1-7 - Energy consumption and mix","29."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","We would appreciate clarity with respect to how we can demonstrate that strategy and business model are compatible with 1.5C, if retained. For targets (as previously required), it is clear how temperature alignment can be provided . This is less clear for strategy and business model. We propose to change back to target alignment. ","E1","E1-1 - Transition plan for climate change mitigation","14."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","We welcome the introduction of 'dependencies' around transition plans aligned to IFRS S2.","E1","E1-1 - Transition plan for climate change mitigation","AR 3"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","We welcome the simplified disclosure requirements and the clear focus on exposure to climate-related hazards and transition events and trends. We recommend to use more general language in 18b) since transition risk scenarios may not be event based (e.g. NGFS scenarios) Change this to \"(b) to transition risk factors (over the short,- medium- and long-term)\". It must allow flexiblity for different types of transition risk scenarios used by banks. We would also ask to reconsider financial institution specific definitions for upstream and downstream value chains.  ","E1","E1-2 - Climate-related risks and scenario analysis","18."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","We agree with amendments to policy disclosures including with respect to GDR-P.","E1","E1-4 - Policies related to climate change","22."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The application requirements do not provide additional guidance to undertakings on how to report energy production metrics; practical examples would be useful, in particular with regard to the inclusion of thermal energy produced by cogeneration. Please provide supplementary guidance through the inclusion of specific application requirements.","E1","E1-7 - Energy consumption and mix","30."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","In relation to the new AR 24(b) on share and types of contractual instruments, we see inconsistency with EFRAG’s stated approach that application requirements should serve as guidance rather than as content requirements. If EFRAG expects companies to disclose information on contractual instruments, it should move such a paragraph to disclosure requirements. Also on this AR, the wording remains unclear with a reference to “share” that is not accompanied by any indications on calculation formula.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 24"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","We welcome the deletion of mandatory requirements around the reconciliation of line items to financial statements as per previous DR 68. ","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41."]
["Excels","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is required to conduct calculation for all type of assets including right-of-use assets. Some right-of-use assets such as intellectual property rights and copyrights do not involve GHG emissions. We request to exclude right-of-use assets that do not emit any GHG from AR30(b).","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","AR 30"]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Information on the potential locked-in emsission provides limited material insights on a company’s decarbonization pathway with information difficult to obtain. We suggest to remove this requirement.","E1","E1-1 - Transition plan for climate change mitigation","14. (c)"]
["Excels","ETSA ","Business association (other than association of financial institution)","Belgium",null,null,"I agree","ETSA members appreciate the closer link between the double materiality analysis and the resilience analysis related to climate change, as they can now be reported as closely connected exercises – rather than individual analyses. \n•\tETSA members believe EFRAG should align its application requirements and NMIG on climate resilience analysis to what is possible with open source climate risk tools, to avoid unnecessary costs for (smaller) preparers.\n•\tEFRAG holds on to the requirement to provide current financial effects related to material risks and opportunities. ETSA members ask EFRAG to provide (or co-develop) supportive (preferably open-source, sector-specific) analytical tools that can help preparers quantify climate and other environmental risks. This can be part of the NMIG, as EFRAG does with proposing tools like Natura2000 or the WWF Risk filter","E1","E1-3 - Resilience in relation to climate change","AR 8"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Disclosing further information on resilience of strategy and business model increases burden","E1","E1-3 - Resilience in relation to climate change","21."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Alignment between operational control boundaries and organisational boundaries might be difficult to achieve","E1","E1-6 - Targets related to climate change","AR 15"]
["Excels","EFPIA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","As revised, this requirement now applies to Scope 1, 2, and 3 emissions. It is inconsistent with the GHG Protocol and is not feasible for Scope 2 and Scope 3. This requirement should align with the GHG Protocol and clarify that it only applies to Scope 1. The three-year grace period provided in Amended ESRS E1 122-125 for value chain data is unlikely to provide enough time for this type of data and/or valid emission factors to become available.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 21"]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","§19 includes a new \"shall\" requirement:\" for paragraph 18(b) it shall include the type of transition event analysed. In conducting its climate -related physical risk analysis supported by scenario analysis, the undertaking shall\". Tha table in AR12 of set was presented as an example, not as a requirement. Those new obligations should be suppressed.","E1","E1-2 - Climate-related risks and scenario analysis","2."]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","§24 a) adds a “shall” disclosure by requesting climate change mitigation actions by decarbonisation lever; this goes too far for operators. This decomposition should be suppressed.","E1","E1-5 - Actions and resources in relation to climate change","5."]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","Option 2 must apply to §40, §41 and §42.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","39."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","Nokia welcomes the clarity on expectations, namely a summary with details in respective other chapters. However, duplicative information is now required and should be removed, e.g. (a) statement of GHG emission reduction targets being science-based which is also expected to be disclosed under E1-6 26(c). Additionally, the reliefs introduced in ESRS 2 - AR 17 should apply throughout the ESRS whenever discussing current or anticipated financial effects or metrics, notably on ESRS E1 - AR 2. A relief should also be introduced to reflect that  public companies have restrictions on what kind of forward-looking information they are allowed to disclose and how such information should be published (e.g., in case future investment and plans that have not been announced yet in line with applicable financial regulations).","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","The proposed text is easier to read but additional clarity is needed: are the companies required to disclose if internal carbon pricing schemes are not in place? Disclosure requirements should be formulated such that companies can focus on relevant and material information, and only in very specific cases required to disclose if certain requirement is not applicable.","E1","E1-10 - Internal carbon pricing","38. (a)"]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially agree\nWe believe it is important that this amendment is further amended with a materiality threshold, as the biogenic emissions should only be required to be reported, if they are material. \n\nNot securing this will put an unnecessary reporting burden on the entities and will not provide decision useful information. \n\nWe propose to amend to ESRS E1, paragraph 33, as a minimum with the inclusion of a 10% threshold inspired by the taxonomy reporting or at least with the inclusion of “material” (changes marked with capital letters: \"33… The undertaking shall disclose its MATERIAL biogenic CO2 emissions from the compulsion or biodegrading of biomass separately from the emission scopes, IF THIS CONSTITUTES MORE THAN 10 % OF THE EMISSIONS.\" \n\nWe also note that the reporting of biogenic emissions are currently not included in the proposed table in AR27.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","33."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I disagree","We find that ‘potential stranded assets’ does not sufficiently delimit the scenarios for what can be considered relevant to users. The datapoint should be limited to ‘anticipated stranded assets’.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (f)"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","The wording is inconsistent with the annex definition of transition plan for climate change. An aspect of an undertaking’s overall strategy that lays out the undertaking’s targets, actions and resources for its transition towards a lower--carbon economy, including actions such as reducing its GHG emissions with regard to the objective of limiting global warming to 1.5°C and climate neutrality.","E1","E1-1 - Transition plan for climate change mitigation","AR 1"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","Reference to NMIG 7:\nIncorporates 'shall' requirements that should be either removed or moved to the main body of E1.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","32."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","RED FLAG: \nThe requirement seems an extension of Delegated Act: The description of “financial and investment planning” (ED) goes beyond “investments and funding” (DA) as the latter is a subset or part of the former. This is further confirmed by the wording “investment and financial planning (including the short- and medium-term financial and investment plan)” in AR 2(c).","E1","E1-1 - Transition plan for climate change mitigation","14. (a)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","(1) We believe that disclosures on resilience should be adressed centrally in ESRS 2.\n(2) The issue is not mature enough to require these detailed specifications. There is no comparability of information on business resilience. E.g., the term \"Resilience analysis\" is not clear. Further, we see the risk of boilderplate disclosures. \n(3) The DR gives rise to diverse understanding of the content which will create high efforts for both preparers and auditors. We do not see simplification and streamlining here.\n","E1","E1-3 - Resilience in relation to climate change",""]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","(1) The DR should make crystal clear that the undertaking is not required to choose one of both alternatives mentioned in this paragraph to present its GHG reduction targets. In practice further ways and less granular presentation were applied for the 2024 reporting.\n(2) Examples should rather be adressed as \"may\" guidance in the NMIG.","E1","E1-6 - Targets related to climate change","14."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","The requirement to present biogenic emissions seperately should - if ever - refer to Scope 1 (delegated act), only, but not to \"all scopes\".  In addition, the requirement should apply to \"material\" biogenic emissions which is not the case in the ED","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","33."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL:\n The wording \"activity data\" is misleading in this context. It shoud read \"on the basis of current data\", instead.\nIn addition, as the term \"GHG inventory\" might be misunderstood, it should be explained in the glossary.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 25"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","Requirement on \"location of key assets at material physical risks\" results in unnecessarily detailed reporting, as depending on the sector, this could involve a large number of locations in all regions of the world. As an example, logistic sector undertakings have much more sites than heavy industry.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","40. (b)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I disagree","We would suggest including this Application Requirement in the NMIG, as it is only a “may” requirement and therefore not mandatory. To avoid confusion regarding the mandatory Disclosure Requirements, we believe it is misplaced in its current location","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 27 for paras. 31 & 32"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The disclosure requirement should be able to be fulfilled in the ESRS 2 section when describing material IROs. Otherwise it would be duplicated. ","E1","E1-2 - Climate-related risks and scenario analysis","17."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The information on achieved and expected GHG emissions should already be provided as part of the Transition Plan, AR 4. Duplication should be omitted. Reporting on actions and resources should be raised to the levers level for achieved and expected GHG emission reductions and quantative short and medium-term CapEx and/or OpEx figures at the level level should be made coluntary as this gets into competitive information like product plans. ","E1","E1-5 - Actions and resources in relation to climate change","24. (b)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We welcome the revisions especially in AR 25 (d); but the disclosure required in AR 25 (g) should be deleted as Cloud computing is only rented through the user company (Scope 3) but already disclosed by the provider (Scope 1) which leads to double counting and high efforts for verification","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 25"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","From our perspective, removing the intensity metric makes sense because the metric involved additional effort, and the comparability of the metric with other companies was not guaranteed.","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","31."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Such estimates are highly challenging because opportunities related to the transition are difficult to quantify accurately. Additionally, due to competitive reasons, we would prefer not to disclose such figures, as they could reveal strategic information and be misinterpreted. ","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","42."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","For anticipated financial effects disclosures, it is critical that EFRAG releases guidance and methodology which clearly outlines how companies can quantitatively and qualitatively disclose these requirements. ","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities",""]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","The amendments increase interoperability with the ISSB which is positive. ","E1","E1-3 - Resilience in relation to climate change","21."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Scope should be much clearer. \"This Standard covers DRs related but not limited to the seven Greenhouse Gases (GHG): carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF6) and nitrogen trifluoride (NF3). It also covers DRs on how the undertaking addresses its GHG emissions as well as the associated transition risks.\" should be a separate paragraph and no need to be duplicated in para 12a.","E1","E1 - Objective","5."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Removed disclosure of only significant capex and opex required for actions – refers to all capex and opex but not clear as ESRS 2 refers to significant financial resources.","E1","E1-5 - Actions and resources in relation to climate change","24. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Requirement to disclose base year and base value indicated as being deleted to allow flexibility. However, this still seems to be an ESRS 2 requirement under MDR-T? Hence is not a deletion. Needs to be clarified. If not a deletion, should not be counted as a deleted disclosure requirement.","E1","E1-6 - Targets related to climate change","26."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","We note that AR30 has shifted from requiring an explanation of the calculation methodology used to mandating the adoption of specified calculation approaches. This change introduces stringent, prescriptive requirements that reduce flexibility and leave little room for materiality-based judgment.\nWhile standardization can enhance comparability, the new approach may not be proportionate for all undertakings, especially where certain inputs are immaterial or where alternative, well-established internal methods already provide reliable results.\n","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","AR 30"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Dependencies are already included under risks. The mention of dependencies should be deleted. ","E1","E1 - Objective","1."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","ANC would favour a deletion of this datapoint as dependencies and locked-in emissions should be part of the explantion of the progress made in the following DP (§14d)","E1","E1-1 - Transition plan for climate change mitigation","14. (c)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Idem, this DP should be applicable only to undertakings active in high impact climate sectors","E1","E1-7 - Energy consumption and mix","29. (b)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","We note that the reference to net zero has been completely removed from the standard. This is regrettable, as prior to ESRS, there was a significant proliferation of net zero communications, each with varying levels of ambition. Such claims were also identified by ESMA in its greenwashing report as a prevalent issue. The inclusion of net zero in Set 1 provided a clear, uniform definition for all actors and led to substantial improvements in disclosure quality and better differentiation from neutrality claims. This concept and its definition should be maintained in the standard.\nProposed wording \n• Add in glossary previous entry “Net-zero target”\n• Retain current Set 1 E1-7 §60 with clarifications regarding removals vs offsets: “In the case where the undertaking discloses a net-zero target in addition to the gross GHG emission reduction targets in accordance with Disclosure Requirement E1-6, it shall explain the scope, methodologies and frameworks applied and how the residual GHG emissions (after approximately 90-95% of GHG emission reduction with the possibility for justified sectoral variations in line with a recognised sectoral decarbonisation pathway) are intended to be neutralised by GHG removals.\"","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","37."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","The clarification of the requirements on the features of the transition plan on targets, actions and resources is seen as a positive clarification.\nWe consider positive the fact that a third-party validation is now introduced. We suggest to include the same possibility to refer to third-party validation with respect to the targets DR (E1-6) for consistency and readability purposes (see comment on §26-e).\nWe request EFRAG to make explicit the requirement that \n-\ttransition plans shall cover Scope 1, 2 and 3 emissions from the group. \n-\tthe coverage of the targets, actions and financial resources need to be consistent, and the time horizons of these elements also need to be consistent (including how the time horizons in E1-1 should be consistent with the time horizons considered in E1-5).","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I disagree","Due to the wording of \"the undertaking shall provide its assessment of its climate resilience at the reporting date\", it can be read as requiring an annual update of the analysis. We suggest specifying that the resilience analysis does not need to be conducted on a yearly basis but shall be revised at regular intervals or whenever necessary due to specific facts and circumstances, such as changes in boundaries. The relation between the timings for the scenario analysis carried out in E1-2 and the resilience analysis in E1-3 should also be clarified.","E1","E1-3 - Resilience in relation to climate change","AR 9"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","Undertakings are no longer required to state the scope 2 method applied to their targets covering Scope 2 (currently required in Set 1 AR24), creating a risk of lack of comparability and transparency across undertakings. We encourage EFRAG to retain this information.\nThe requirement to disclose the share of each scope is maintained which creates challenges for undertakings with combined targets. Such disaggregation is not required in recognized target setting frameworks or IFRS. We encourage EFRAG to remove this requirement, as it is not always practical to disaggregate combined targets, due to mixed effects (reducing scope 1 by electrification increases scope 2 emissions). \n\nEditorial comment: we suggest EFRAG to clarify how 26(a) applies for companies that have only set intensity GHG emission reduction targets. Based on AR 12, it is unclear whether 26(a) fully applies when only intensity targets have been set  , including the coverage of the targets.","E1","E1-6 - Targets related to climate change","26. (a)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","We ask EFRAG to clarify AR 17(a) in relation to the organizational boundaries considered in E1-8. It is unclear how the concept of 'same organizational boundary perimeter applied for reporting GHG Scopes 1 and 2 emissions' should be applied due to the mandatory reporting boundary based on financial control and the additional conditional boundary based on operational control. This could be interpreted as either referring to financial control only (the default approach), or, potentially, requiring a double reporting of energy consumption (if such double reporting is required for GHG reporting based on the fair presentation concept), which would go against the principle of simplification.\nWe also ask EFRAG to revise AR 17(j) to allow undertakings to consider as “renewable” the renewable energy in a residual mix. The current wording creates difficulties for reporting and audit, and potential misalignment between E1-7 reporting and Scope 2 reporting.","E1","E1-7 - Energy consumption and mix","AR 17"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","Even though not necessarily related to carbon credits, insets are also an emerging mechanism used by many companies to offset or reduce emissions in the upstream/downstream value chain. The standard should include clarifications on whether these should be seen as carbon credits (with no implications on gross emissions) or whether these could be considered decarbonization levers with effects on gross emissions.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","36."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","This paragraph mentions the possibility of using carbon credits for neutrality claims. Considering possible deviation and interpretations around what it means to have a carbon neutrality claim, we suggest that EFRAG includes the definition of carbon neutrality in an AR or in the glossary .\nSee previous comment on reintroduction of net zero target disclosures.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","37."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","See comment on time horizons\nWe suggest that EFRAG specifies revenue as being the net revenue disclosed in the financial statements.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","40. (d)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The alignment regarding the 1.5°C target has shifted from specific taregts to a broader focus on strategy and business models. This change introduces additional effort and complexity, as the terms \"strategy\" and \"business model\" are inherently flexible and open to interpretation.\nThis flexibility allows for extensive discussions with auditors, but it does not provide any added value compared to the previous target-oriented approach. The taregts were integral to the strategy and were already aligned with the business model. Therefore, maintaining a clear focus on the alignment of targets is essential for effective alignment and implementation.","E1","E1-1 - Transition plan for climate change mitigation","AR 1"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","AR 2: See consultation E1-14.a. \n\nAR 2(a): \n\nAR 2.b: It is not clear why the requirement was moved to ARs. Complicates the reading of the standard, as it is a mandatory specification. \n\nAR 2.c:  Some of the disclosures expected by the ESRS cover sensitive information from a strategic perspective, disclosure of which could be used to their disadvantage by non-EU competitors of EU issuers that are under no such transparency obligations. The current wording of the exemption for disclosure of sensitive information should be revisited as it is currently too stringent to be used to safeguard business secrecy, especially in an international business environment that risks becoming even tenser.  Information on future investment projects is sensitive, and its disclosure may have a severe impact on the competitiveness of the preparer. All data points regarding significant CapEx and OpEx amounts should be deleted. Information on future investment projects is sensitive, and its disclosure may have a severe impact on the competitiveness of the preparer. \nNew Wording \"While this information helps demonstrate the coherence and credibility of the transition plan, there is no expectation that the undertaking disclose all internal information used to manage the plan.\" is not solving that above named issue. ","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","\"In cases where the undertaking has only set a GHG intensity reduction target, it shall nevertheless disclose the associated absolute values for the target year and interim target year(s).\" This requirement forces companies to disclose the planned volume growth. This puts them at a massive competitive disadvantage and cannot be published in this way.","E1","E1-6 - Targets related to climate change","AR 12"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We believe it is nearly impossible to reliably calculate the monetary amount and percentage of net revenue at risk from physical climate impacts before considering adaptation measures. The complexity arises from the high uncertainty of climate projections, the difficulty in quantifying future physical damages, and the challenge in accurately modeling how risks will evolve over time. Additionally, the lack of standardized methodologies and reliable data further complicates such estimations.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","40. (d)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We believe that estimating the monetary and percentage impact on net revenue from transitional risks before considering mitigation and adaptation measures is highly challenging. Given the high uncertainty surrounding future policy changes, technological developments, and market shifts, it is more meaningful to incorporate measures into the assessment. Disclosing risks without accounting for planned actions may be misleading and fail to provide an accurate picture of the true risk exposure.","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","41. (a)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Reporting on dependencies is logical but requiring firms to report on locked-in GHG emissions will lead to undue cost and burden, especially for those firms not in the energy sector. Recommend removing the locked-in emissions DR and maintaining the transition plan dependencies DR. This change provides the same level of information that stakeholders are interested in, yet avoids too granular of a disclosure which is not actionable or comparable.  ED ¶14(c) & AR 3 vs. 2023 ¶16(d) & AR 3.  Adds explicit requirement to disclose “dependencies” (e.g., technology deployment, market demand, policy assumptions) on which the transition plan relies.  Increase rather than reduce/simplify disclosure burden; qualifying language (“shall include”) remains prescriptive and does not create real flexibility.","E1","E1-1 - Transition plan for climate change mitigation","14. (c)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree"," Doesn’t appear to be any revision to account specifically for the FI sector, and the “areas of uncertainty” concept now has been included in the substantive requirement under §21 (when we think it should be excluded). KOCH - ED ¶21(a)-(c) & AR 8-10 vs. 2023 ¶19 & AR 6-8.  Adds two new qualitative datapoints (requirement to disclose “significant areas of uncertainty” in resilience assessment and “capacity to adjust” business model).   New uncertainty and capacity disclosures add subjective narrative burden without reciprocal relief elsewhere.","E1","E1-3 - Resilience in relation to climate change","21."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","No substantative content change.  Merely relabels former DR E1-2.  Administrative change only.","E1","E1-4 - Policies related to climate change","22."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," Exposure draft drops subsection on energy-intensity per revenue (2023 ¶¶40-43 & AR 36-38). Eliminates one quantitative KPI & reconciliation; tangible reduction in burden (especially for service entities).  Simpllification is isolated – comparable deletions for other intensity metrics (GHG intensity) needed to yield meaningful simplification.","E1","E1-6 - Targets related to climate change","27."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," Deletes mandatory GHG-intensity per revenue KPI (2023 ¶¶53-55 & AR 53-55).  Meaningful simplification to remove a commly crtiized intensity metric and related financial reconciliation however comparable datapoints persist elsewhere (e.g., energy).","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","31."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,null,"The organizational boundary to be used in disclosing paragraph 32 shall consider aligning with either ISO 14064-1 or GHGP Corporate Standard (2004), allowing companies the option to choose between a financial-control or operational-control boundary. AR 18 19 and 21 be aligned when it comes to reporting boundary. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 19"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Need clarification on what is considered \"in\" its operations, upstream or downstream value chain versus \"out\". Introduces new quantitative datapoint adding  complexity.  Makes disclosure of \"reversals\" of removals mandatory where previously it was optional guidance.","E1","E1-9 - GHG removals and GHG mitigation projects financed through carbon credits","35."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","former 10. (b) it needs to be clarified that undertakings may cross reference to other topicl standards, if neccessary . Combining all topics will highly increase workload and diverge from the material topics","E1","E1-1 - Transition plan for climate change mitigation","13."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","anticipated financial effects are hypothetical to anticpate before measures have been taken and do not contain any valuable information","E1","E1-11 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities","40."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"24. Recommend making this optional in some manner - \n“shall include the achieved GHG emission reduction and should include the expected GHG emission reduction”","E1","E1-5 - Actions and resources in relation to climate change","24."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"24.c Make inclusion of CapEx and OpEx optional. Active CapEx/OpEx beyond what's already included in financial disclosures might be business sensitive and challenging. Anticipated CapEx/OpEx would be hard to quantify and sensitive to disclose, especially at certain levels of granularity.","E1","E1-5 - Actions and resources in relation to climate change","24. (c)"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"The organizational boundary to be used in disclosing paragraph 32 shall consider aligning with either ISO 14064-1 or GHGP Corporate Standard (2004), allowing companies the option to choose between a financial-control or operational-control boundary. AR 18 19 and 21 be aligned when it comes to reporting boundary. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 19"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The disclosure of \"financial and investment planing (including the short- and medium-\nterm financial and investment plan)\" and \"financial resources supporting the implementation and strategic ambition of its transition plan for climate change mitigation, including quantitative short- and medium-term CapEx, and/or OpEx figures, as well as \nanticipated long-term CapEx and/or OpEx ranges\" go  beyond the initial requirements and the changes therefore go against the aim of simplifying the ESRS. Additionally, it is unclear how the short-/medium-term and long-term  time horizons are defined considering also the respective GHG targets defined by the companies. Does long-term refer to 2050? Disclosing any investment figures until 2050 is not feasible and the information would not be reliable. Requirements related to Transition Plans should be closely aligned with existing international frameworks.","E1","E1-1 - Transition plan for climate change mitigation","AR 2"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","The disaggregation must be optional as like GHG Protocol","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 26"]
["Excels","Reclaim Finance","NGO","France",null,null,"I agree","The AR notes that \"Information on dependencies relate to, e.g. deployment of certain technologies, market demand or policies\". The final mention of \"policies\" is highly relevant but we note that the DR and AR do not require entities to provide elements on how their public advocacy activities and the activities of their representative bodies align with their plans and/or assumptions. This gap should be adressed in the transition planning section.","E1","E1-1 - Transition plan for climate change mitigation","AR 3"]
["Excels","Reclaim Finance","NGO","France",null,null,"I agree","We strongly agree with the requirement to disclose in absolute terms for all scopes, with the possibility to also disclose intensity targets. We note this requirement should be adjusted for financial institutions as explained in our comment on E1-25.","E1","E1-6 - Targets related to climate change","26."]
["Excels","ASD","","",null,null,"I agree","In E2-4, the current paragraph 26 that requires undertaking to disclose the microplastics it generates or uses was deleted in the Exposure Draft. Moreover, the new paragraph 16 of the Exposure Draft requires to report information on secondary microplastics in a qualitative or quantitative manner, including through estimates. We welcome EFRAG proposed changes.","E2","E2-4 - Pollution of air, water and soil","16."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","- Disproportionate costs.\n- Substances of concern:  Data not currently available and continous changing classification/ uncertainties; status of labeling/ substance of concern can change during processing as reactive groups disappear leading to a non labelled article for users at the end.\n- Disclosure requirement E2-5 on substances of concern (SoCs) and substances of very high concern (SVHCs) also risks becoming excessively burdensome and does not adequately provide an understanding of the impact of the undertaking on health and on the environment. Disclosing total amounts of substances is not necessarily a proxy for actual and potential environmental impacts, as for each substance it is necessary to consider its use, its application, and how it is handled.\n- It is suggested to qualify this requirement as qualitative or to consider adopting a phase-in approach.\n","E2","E2-5 - Substances of concern and substances of very high concern","17."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Problem: Unclear and disproportionate obligations\nThe revised drafting introduces extensive role-differentiation (manufacturer/importer and user). While under REACH companies may also hold multiple roles, these apply to specific substances and do not require duplicate reporting of the same material flow. By contrast, the ESRS wording could be read as requiring companies to report identical flows multiple times under different roles. This creates duplication and complexity that appear to go beyond the legislator’s stated intention, which was to provide relief for non-chemical companies. In practice, the text risks tightening obligations for chemical companies, creating unnecessary complexity and diverging from the intended objective.\n\nProblem: Lack of consistent thresholds creates legal uncertainty \nThe ESRS draft introduces disclosure obligations for SVHC and SoC without consistently applying clear, harmonized thresholds. While a 0.1% threshold is foreseen for SVHC in articles, no uniform rule exists for SVHC in mixtures or for SoC. This inconsistency creates uncertainty for companies in determining which concentration levels would trigger reporting duties. ","E2","E2-5 - Substances of concern and substances of very high concern","18."]
["Excels","Michelin","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Pollutants to be considered are first the ones from Annex II of EU 2024/1244 and only if relevant the ones identified by the undertaking. Additional disclosure should be only done if relevant.","E2","E2-4 - Pollution of air, water and soil","AR 2"]
["Excels","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States",null,null,"I disagree","The generation of secondary microplastics though equipment wear is extremely difficult to calculate, even qualitatively. Microplastic generation should be defined in terms of equipment manufacturer's plastic content and manufacturer's end of life treatment. Making this a general requirement for all organization’s risks significant double counting, and the lack of a defined qualitative assessment standards or methodologies will cast doubt on the ability to compare results across companies. This requirement should be removed","E2","E2-4 - Pollution of air, water and soil","AR 5"]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","The new version of DR E2-5 maintains its focus on substances of concern, while introducing a more segmented and operational structure that clearly distinguishes between manufacturers, importers, and users. This approach improves the clarity and accuracy of reporting, particularly in relation to REACH regulation obligations. The level of granularity has increased, with specific requirements for different types of economic actors and forms of environmental release.\n","E2","E2-5 - Substances of concern and substances of very high concern","17."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","In the Log of Amendments, it is stated that ESRS E2 now includes pollution from waste (one source of pollution used to estimate emissions to air), since ESRS E5 has no specific requirement on pollution generated by waste. However as the standard only requires air pollution from own operations, we suggest clarifying which waste-related emissions should be accounted for, as some may be downstream emissions (e.g., waste sent to landfills managed by third parties). In ESRS E3 on water, AR 4 clarifies that transfers of water pollutants to external treatment plants qualify as pollution in the downstream value chain.","E2","E2 - Interaction with other ESRS","11. (d)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","AR3 allows for the use of thresholds that apply exclusively to the E-PRTR pollutant list. However, there is a potential risk that auditors may request reporting of pollutants from permitting without applying any thresholds as it is not mentioned. It should be clarified that thresholds may also be applicable to pollutants from permitting. Our suggestion is to clarify in AR3 that a comprehensive materiality assessment—based on the specificity of business processes and operations—can determine which pollutants are relevant for disclosure.\n\nWe agree that only those pollutants emitted by technical installations from Annex II of 2024/1244 have to be reported. \nComment: It is not clearly defined what is meant with \"applicable to the undertaking\". \nSuggestion: Focusing on environmental installation permits and the relevant installations/ Activities (in Accordance with Annex I of 2024/1244; Policy 2010/75/EU Annex I) would facilitate a globally consistent approach and would justify the selection of pollutants that need to be measured. \nSuggested text: \n“The pollutants to be considered for reporting under E2-4, paragraph 16 (a) are those from Annex II of Regulation (EU) 2024/1244 (Industrial Emissions Portal Regulation) that are\napplicable to the undertaking in accordance with measurement requirements based on environmental permits or Annex I of Regulation (EU) 2024/1244 (Industrial Emissions Portal Regulation). It can include additional pollutants that it considers material.”\n","E2","E2-4 - Pollution of air, water and soil","AR 3"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Requiring split by hazard class is not the first information required by stakeholdhers. Priority should be disclosing global information on SVHC in quantity.","E2","E2-3 - Targets related to pollution","AR 7"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The location-based approach to environmental impacts proposed in the standards is disproportionate and should be entirely eliminated. It introduces unnecessary complexity, increases the reporting burden, and does not align with the principles of relevance and proportionality.","E2","E2 - Objective","10."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","Points (c) and (d) that refer to reporting on primary and secondary microplastics shall be presented as sub-§ of points (b). Besides, we recommend clarifying what “directly released into the environment\" refers to with respect to the requirement of a \"separate\" reporting on primary microplastics. The definition of the latter concept that is included in the ESRS glossary implies indeed that all primary microplastics result in a release into the environment.","E2","E2-4 - Pollution of air, water and soil","16. (b)"]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I disagree","I see no reference to targets anymore. All indicators seem to be deleted. I propose to keep the requirement to disclose a target in.","E2","E2-3 - Targets related to pollution","3."]
["Excels","Anthesis Group","Consultant (including software vendor)","United Kingdom",null,null,"I agree","improved wording. The elimination fo the obligation to split into main hazard classess reduces the preparatory work for companies","E2","E2-5 - Substances of concern and substances of very high concern","19."]
["Excels","Jernkontoret","Business association (other than association of financial institution)","Sweden",null,null,"I partially agree and partially disagree","The word 'procured' should be replaced with 'imported' to ensure alignment with REACH and clear interpretation by the company chemical experts on what is covered by this paragraph.\nProposed text: \"18. Manufacturers and importers of SoCs and/or SVHCs on their own and in mixtures shall disclose the total weight of those SoCs, and separately, the total weight of those SVHC, that are: \n(a) imported or manufactured as substances of their own or in mixtures;\"","E2","E2-5 - Substances of concern and substances of very high concern","18. (a)"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","9f addresses primary microplastic exclusively. By requesting information on secondary microplastic, DR 16d is not in line with the definition of 9f and should be deleted, accordingly. ","E2","E2-4 - Pollution of air, water and soil","16. (d)"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","This datapoint supposes that undertaking shall justify the local materiality of pollutants. As a clarification, it should be specified that aggregation at the group level remains possible.","E2","E2 - Objective","10."]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I disagree","The notion of \"importer\" should be cleraly defined.","E2","E2-5 - Substances of concern and substances of very high concern","20."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","Many undertakings act in more than one capacity for the same substance within the same period (e.g., importing a substance and then using it in production). There is no clear guidance on whether such quantities should be reported twice in different datapoints. We recommend clarifying what quantities should be reported in the application requirements.","E2","E2-5 - Substances of concern and substances of very high concern","19."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","The DR should be replaced by \"microplastics release\" as per the comment above. \"release\" Should be added also in the text of AR 1 Para. 16","E2","E2-4 - Pollution of air, water and soil","16. (b)"]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","Para. 18 and 19 - Equinor welcomes the proposed approach in paragraphs 18 and 19 to limit the reporting of Substances of Concern (SoC) to manufacturers (chemical producers), assigning the full reporting obligation to chemical producers (paragraph 18) while excluding users from this requirement (para 19). Considering the breadth of the SoC list and the significant, potentially disproportionate reporting burden for actors outside the chemical sector, we regard this as a reasonable and proportionate solution.","E2","E2-5 - Substances of concern and substances of very high concern","18."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","we would suggest to align this disclosure requirement to GRI 305-7","E2","E2-4 - Pollution of air, water and soil","15."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I agree","Removal is welcome as other regulation already drives the requirements regarding ESG risk management and there is no need to further address this within ESRS, especially for the financial services sector.","E2","Disclosure Requirement E2-6 - Anticipated financial effects from material pollution-related risks and opportunities","n/a"]
["Excels","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom",null,null,"I partially agree and partially disagree","The disclosure of dependencies has been further weakened (to ‘when relevant’) in the new paragraph 1. \nThe TNFD suggests to remove the specification ‘when relevant’ in paragraph 1 and reinstate, either at the level of ESRS 2 or at the level of the individual topical standard, a similar text to the Set 1 paragraphs, such as the one asking for disclosure of ‘the nature, type and extent of the undertaking’s material (…) dependencies (…) related to [pollution], and how the undertaking manages them’.","E2","E2 - Objective","1."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree"," New explicit data point secondary microplastic without methodology\nProblem: Lack of harmonized measurement methods and reporting guidelines\nThe amended provisions require companies to disclose information on secondary microplastics, while it is acknowledged that no harmonized measurement methods or reporting guidelines currently exist. Reliance on qualitative disclosures and company-specific estimates introduces uncertainty and risks undermining reporting integrity. ","E2","E2-4 - Pollution of air, water and soil","15."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","- Disproportionate costs.\n- Substances of concern:  Data not currently available and continous changing classification/ uncertainties; status of labeling/ substance of concern can change during processing as reactive groups disappear leading to a non labelled article for users at the end.\n- Disclosure requirement E2-5 on substances of concern (SoCs) and substances of very high concern (SVHCs) also risks becoming excessively burdensome and does not adequately provide an understanding of the impact of the undertaking on health and on the environment. Disclosing total amounts of substances is not necessarily a proxy for actual and potential environmental impacts, as for each substance it is necessary to consider its use, its application, and how it is handled.\n- It is suggested to qualify this requirement as qualitative or to consider adopting a phase-in approach.\n- Suppliers outside Europe typically follow local chemical regulations, meaning EU-specific regulations are not legally recognized or applied. For the sake of simplification and consistency, SoCs should not be included as a general requirement for all stakeholders. ","E2","E2-5 - Substances of concern and substances of very high concern","17."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","General comment: EFRAG should develop comprehensive non-mandatory implementation guidance for each topical standard, including ESRS E2. The guidance should comprise instructions and examples how to conduct the materiality assessment for the topic, how to apply the disclosure requirements, and to calculate the metrics. Sectoral examples could be added, where appropriate.","E2","E2 - Objective","1."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Support the removal of point (iii) from the definition of “Substances of Concern” in  Annex II. \nHowever, it introduces a new definition of Substances of Concern that is not aligned with existing frameworks, creates confusion and contradicts the ESRS review’s objective of simplification. \nEFRAG’s proposal does not consider sustainability-related aspects and focuses on hazard properties only, an area where REACH should remain the primary legislative framework \nThe broad scope of point (ii) would make information gathering highly challenging, creating additional administrative burden – especially for non-European operated sites\nSVHCs ((i)) are well-defined hazard categories, with existing processes for substances that pose significant, scientifically recognized risks to human health or the environment. Referencing SVHCs ensures clarity, consistency, regulatory alignment, and practical usability for businesses operating within or exporting to the EU. This approach promotes risk awareness, encourages substitution, maintains regulatory control, and protects environmental health. The SVHC Candidate List is regularly updated by ECHA, ensuring the definition remains relevant and reflects the latest scientific and regulatory developments. It is therefore recommended to remove the definition of SoC from the list of definitions and to limit the disclosure obligations under E2-5 (items 17, 18, 19, and 20) to SVHCs as defined under REACH.","E2","E2-5 - Substances of concern and substances of very high concern","17."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","It is recommended that the disclosure requirement E2-5 (18, 19 ) is streamlined to focus on SVHCs only. The list of SoC is too fluid for reporting purposes. Next to that the concept of SoC is EU focused and complex to apply outside EU.\nThe broad scope of SoC would make information gathering highly challenging, creating additional administrative burden – especially for non-European operated sites\nSVHCs are already well-defined hazard categories, with existing processes for substances that pose significant, scientifically recognized risks to human health or the environment. Referencing SVHCs ensures clarity, consistency, regulatory alignment, and practical usability for businesses operating within or exporting to the EU. This approach promotes risk awareness, encourages substitution, maintains regulatory control, and protects environmental health. The SVHC Candidate List is regularly updated by ECHA, ensuring the definition remains relevant and reflects the latest scientific and regulatory developments","E2","E2-5 - Substances of concern and substances of very high concern","18."]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","[3] The disclosure requirements in E2-4 should focus on microplastics leaving the undertaking's facilities as emissions rather than products. The DR should be replaced by \"microplastics release\" as per the comments above. \"release\" Should be added also in the text of AR 1 Para. 16.\nIn sum, we recommend EFRAG to delete the proposed disclosure requirement on secondary microplastics in ESRS E2 paragraph 16(d) alongside the definition of secondary microplastics in Annex II.","E2","E2-4 - Pollution of air, water and soil","16."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","inclusion of the 0.1% threshold (as per REACH) for substances in articles simplifies information obligations for articles, since REACH regulation already requires this information to be exchanged between suppliers and their clients. ","E2","E2-5 - Substances of concern and substances of very high concern","20. (b)"]
["Excels","ArcelorMittal","Preparer (non-financial preparing a sustainability report)","Luxembourg",null,null,"I partially agree and partially disagree","Suggest modifying paragraph 18, point (a), to: \"imported or manufactured as substances on their own or in mixtures;\"\n==> Justification ==> ‘Procured’ is not a term used under REACH. To have a better alignment with REACH terminology, it is recommended to replace ‘procured’ by ‘imported’.","E2","E2-5 - Substances of concern and substances of very high concern","18. (a)"]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I disagree","Reporting on SoC must be suppressed as there is no official, stabilised definition. Moreover, to require undertakings to disclose SoC goes beyond what is required by REACH and creates a significant additional burden (over three thousand substances should be considered). Therefore, we call for the suppression of the reporting on SoC, as proposed by the French Accounting Standards Authority.","E2","E2-5 - Substances of concern and substances of very high concern","18."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I disagree","The primary boundary is the financial consolidation (reporting undertaking) but AR19 requires operational-control reporting if the financial boundary fails to fairly present operated assets. No clear tests or quantitative thresholds for when the “fails to convey a fair presentation” trigger applies. That creates inconsistent choices and reconciliation issues (Scope 1/2 reported on two boundaries) that auditors will need to assess. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 19"]
["Excels","BDO Poland","Auditor","Poland",null,null,"I disagree","AR25(e) requires updating Scope 3 categories every year for significant categories and full inventory at least every three years, but the screening rules for “significant” categories are wide (magnitude + other criteria). The lack of clearer thresholds (e.g., % of total emissions, spend thresholds) will create year-to-year comparability problems and put heavy supplier data collection burdens on companies. Auditors will have to rely heavily on estimates and sampling with limited guidance on acceptable estimation techniques. ","E1","E1-8 - Gross Scopes 1, 2, 3 emissions","AR 25"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","We support the simplification of the requirement, as this avoids duplication with some overarching requirements in ESRS 2.","E2","E2-2 - Actions and resources related to pollution","13."]
["Excels","ETSA ","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","\tWhen it comes to the calculation and reporting of pollutants emitted, ETSA members express concerns about allowing companies to use their own methodologies for measurement and reporting. While flexibility can be beneficial, it could lead to a lack of comparability. A suggested solution would be to mandate measurement practices according to local and national legislations, which are already officially recognized and account for the local context. ","E2","E2-4 - Pollution of air, water and soil","AR 2"]
["Excels","TEPPFA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The Disclosure Requirement E2-4 Article 16(b)(i) aimed at disclosing the total volume of microplastics manufactured or used in products, based on the REACH definition and scope, will impose a significant additional burden on companies. Operators are already required by Commission Regulation (EU) 2023/2055 to provide detailed disclosures, including annual emission estimates of synthetic polymer microparticles to ECHA. In addition, the new Pellet Loss Regulation (based on the provisional agreement of 13 May 2025) will require operators to disclose on the quantities of pellets handled and released to the environment. This requirement effectively adds another layer to existing legal obligations, further increasing the gap in harmonization between regulations, which will ultimately create confusion and resource burden for operators, especially for SMEs, potentially undermining efforts to comply consistently and effectively. Better alignment and integration with existing legal frameworks such as REACH and the Pellet Loss Regulation would support clarity, reduce duplicative efforts, and improve data quality and comparability for all stakeholders.","E2","E2-4 - Pollution of air, water and soil","16. (b)"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Disclosing SoC and SVHC by hazard class is heavily burdensome for companies because it will require companies to report in double counting","E2","E2-5 - Substances of concern and substances of very high concern","AR 7"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The addition of a new disclosure layer on microplastics in the downstream, introduces unnecessary reporting burden.","E2","E2-4 - Pollution of air, water and soil","16."]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","It should be noted that the Regulation (UE) 2024/1244, which introduces three new pollutants in its Annex II, will enter into force at 1st january 2028. In addition, the sentence \"It can include additional pollutants that it considers material\" should be deleted in order to avoid unnecessary debates. This provision is not considered necessary, since undertakings can disclose entity-specific information if they want to do so.","E2","E2-4 - Pollution of air, water and soil","AR 2"]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","This datapoint asks for a disclosure that goes beyond what is requiered by Article 33 of the REACH Regulation. Indeed, Art 33 does not compel operators to quantify SVHC, but only to specify the substances concerned by nam. Therefore, this paragraph should be amended accordingly.","E2","E2-5 - Substances of concern and substances of very high concern","20. (b)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,null,"Disclosure requirement E2-5 on substances of concern (SoCs) and substances of very high concern (SVHCs) also risks becoming excessively burdensome and does not adequately provide an understanding of the impact of the undertaking on health and on the environment. Disclosing total amounts of substances is not necessarily a proxy for actual and potential environmental impacts, as for each substance it is necessary to consider its use, its application, and how it is handled. ","E2","E2-5 - Substances of concern and substances of very high concern",""]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","Undertakings should not be obliged to report on releases of SoCs/SVHCs into the environment (air, water and soil) that go beyond what they already are reporting according to approval of production sites and according to requirements from regulations on emissions, e.g. IED, IEPR.","E2","E2-5 - Substances of concern and substances of very high concern","18. (c)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","N.a.","E2","E2-4 - Pollution of air, water and soil","16."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We agree that the material pollutants to be considered for reporting can be defined by the thresholds for releases in Annex II of 2024/1244.","E2","E2-4 - Pollution of air, water and soil","AR 3"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","N.a.","E2","E2-5 - Substances of concern and substances of very high concern","19."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","The current ESRS definition of microplastics diverges from REACH. The ED partially aligns the two but the ED does not include the derogations in place under REACH. For example, for paint and coatings, film-forming processes as part of application mean that certain microplastics are subsequently no longer classified as such under REACH. As there are no such derogations under the ED this will result in a significantly wider scope and materially increased reporting requirements. We therefore request EFRAG to align the definition and reporting requirements under the ESRS ED fully with REACH.","E2","E2-4 - Pollution of air, water and soil","16. (b)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Mention the connection with AR 22 of ESRS 2 (e.g., local considerations such as air, water, and soil quality), and include 'pollutant incidents and deposits with material impacts' as an additional example (and potential item for disaggregation)","E2","E2 - Objective","10."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","This comment is on E2.16(d).\nThe distinction between the disclosures required for primary (where quantitative information will be necessary) and secondary (where only qualitative information will be requested) microplastics improves clarity on the definition of microplastics which therefore includes those intentionally manufactured/used, and those (unintentionally) generated from the products, thus enhancing comprehensibility and applicability. In addition, guidance on the identification, assessment and quantification of secondary microplastic would improve topic clarity and applicability.","E2","E2-4 - Pollution of air, water and soil","16."]
["Excels","Dragerwerk AG &Co.KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","There is currently no uniform, legally binding definition for this group of substances, nor is there an official list of substances. Some hazard classes according to CLP regulation are not introduced in other parts of the world. The term is used in various EU initiatives such as the Ecodesign Regulation and the EU Taxonomy, but remains context-dependent and open to interpretation. Due to this lack of clarity, mandatory information on SoC should be removed from the ESRS, as it cannot be reliably implemented by companies.","E2","E2-5 - Substances of concern and substances of very high concern","18."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","N.a.","E2","E2-3 - Targets related to pollution","14."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","N.a.","E2","E2-5 - Substances of concern and substances of very high concern","18."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","N.a.","E2","E2-5 - Substances of concern and substances of very high concern","20."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," ED §17(b)-18 vs 2023 §40(a)(iii)-(g), §40(b)-(d).  Partial simplification.  Retains fossil fuel/chemicals/controversial weapons/tobacco statement.  Eliminated revenue table, headcount and reconciliation.  Revenue breakdown by ESRS sector deleted; only “list of significant sectors” now required. Headcount by geography, banned products, explicit sustainability goals, and IFRS 8 reconciliation deleted. ","ESRS2","ESRS 2 - SBM-1 - Strategy, business model and value chain","17. (b)"]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The current design of the SoC/SVHC disclosure risks missing its stated objective of helping users understand material impacts on health and the environment. Reporting overall hazard-based volumes without exposure or risk context can mislead stakeholders, as it ignores whether risks are effectively controlled. \nFor instance, many metals are intrinsically classified as hazardous but are used safely under strict exposure controls. This creates reputational risks, especially for Green Deal-critical materials such as cobalt, nickel, lead, and PGMs, which are essential for renewable energy and recycling but are still flagged as hazardous. \nIt remains unclear whether the disclosure is intended to map potential regulatory risk (substances likely to face restrictions) or to quantify hazardous flows in society. In its current form, it achieves neither goal effectively and risks undermining both comparability and stakeholder understanding.","E2","E2-5 - Substances of concern and substances of very high concern","17."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","- Companies in the scope of the Industrial Emission Directive shall reported under Regulation (EU) 2024/1244 (Industrial Emissions Portal Regulation). This would ensure legal consistency, avoid regulatory overlap and reduce the reporting burden. There is no need to include any additional pollutants.\n- While pollutant selection based on materiality is reasonable, expanding disclosures to include local-level environmental permits massively broadens the scope of emissions and prevents standardisation across companies.","E2","E2-4 - Pollution of air, water and soil","AR 2"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"It is unclear whether the 20(a) obligation to disclose the quantity of SVHCs above 0.1% w/w in procured components only apply to components that procured in the EU. Recommend clarifying that it only applies within the EU.","E2","E2-5 - Substances of concern and substances of very high concern","20. (a)"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","As a clarification, we need more certainty to ensure information required under this paragraph, combined with the paragraph 3.1 from ESRS 1, let the operator the possibility to report only relevant emissions of specific substances and not all emissions coming from all substances. ","E2","E2-4 - Pollution of air, water and soil","16. (a)"]
["Excels","ASD","","",null,null,"I partially agree and partially disagree","We call to delete E3-4_03  and E3-4_04 because they are redundant","E3","E3-4 - Water metrics","17. (e)"]
["Excels","International Association of Drilling Contractors","Business association (other than association of financial institution)","United States",null,null,"I partially agree and partially disagree","text should be amended to identify that disclosure of water related targets should only be required if they are established - this should not be a mandatory disclosure","E3","E3-3 - Targets related to water","15."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Please clarify the quality of water. Total water generally refers to the sum of all water volumes of all qualities (e.g. fresh, brackish, …); while this metric (the sum of all water volumes of whatever quality) seems less appicable to storage or recycling or consumption (in particular if related to a freshwater aspect such as water stress). A clear reference to freshwater in the metrics would be in line with NMIG 4 for para.15 relative to the targets.","E3","E3-4 - Water metrics","17."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We suggest EFRAG specify that areas at water risk, including areas of high-water stress, referred to in ESRS E3 with respect to the disclosures of key actions and water consumption concerns only areas that are currently affected. Areas that could be affected by water risks in the future should however be considered in the climate resilience analysis that is reported upon under DR E1-3.","E3","E3 - Interaction with other ESRS","10. (a)"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","General comment: EFRAG should develop comprehensive non-mandatory implementation guidance for each topical standard, including ESRS E3. The guidance should comprise instructions and examples how to conduct the materiality assessment for the topic, how to apply the disclosure requirements, and to calculate the metrics. Sectoral examples could be added, where appropriate.","E3","E3 - Objective","1."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","The water metrics proposed in amended E3-4 need to be specified and clarified to avoid diverging interpretations: \n1.\tThe definition of water withdrawals should explicitly mention the sources to be included in the metric, i.e. surface water, groundwater, municipal water, marine water, collected rainwater, reclaimed water from external sources.\n2.\tWater withdrawals should be disaggregated by source as the water source significantly determines the related environmental and social impact (e.g. water withdrawn from  groundwater vs. reclaimed water from a business partner). Especially, marine water withdrawn, consumed or discharged should be reported separately from freshwater.\n3.           Water consumption should be separately reported for areas of high-water stress (instead of areas at water risk).\n4.\tDelete the distinction between water reused and recycled as it is not necessary (both relate to the reuse of water within an undertaking’s organizational boundaries).\n5.\tTotal water stored could be deleted as individual disclosure requirement;","E3","E3-4 - Water metrics","17."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","When disclosing indicators regarding \"total water consumption in areas at water risk,\" the imprecise definition of these areas and the lack of methods for identifying them may be problematic. The definition mentions \"one or more water bodies,\" but it is unclear whether this refers only to status of surface water, groundwater, or both.","E3","E3-4 - Water metrics","17. (b)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","we would suggest to add in AR some public and available tools that allow undertakings to identify areas at water risk","E3","E3-3 - Targets related to water","11."]
["Excels","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We disagree with this new (!) data point. As a matter of principle, no new data points should be included in the revised ESRS. \nThis data point also places a heavy additional burden on companies, as the reporting level would become highly disaggregated if reporting had to be done at the location or asset level. Furthermore, information on PAT is generally not specific to a location or asset level, but rather at a higher level. Reporting at such a low level of aggregation would therefore not be effective. ","E3","E3 - Objective","9."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Comment to deleted AR1 (Set 1 as per DA 2023): Reference to ESRS 1 AR 7 is wrong, there should be a reference to ESRS 2 AR 22","E3",""]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","The [Draft] requirement on water policies should refer to areas of high-water stress. The concept of “areas at water risk” should instead be moved to the provisions for the materiality assessment (see comments for ESRS 2 IRO-1).","E3","E3-1 - Policies related to water","12."]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We support the changes proposed.","E3","E3-2 - Actions and resources related to water","2."]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I disagree","Companies consider the data for water withdrawal is not possible to provide as there are no corresponding water meters. Most industrial companies calculate their water consumption through estimations and modelling rather than by using the water balance approach (i.e., the difference between water withdrawals and discharges). Consequently, turning this \"may\" datapoint into \"shall\" datapoint does not align with the principle of simplification. On the contrary, it would introduce greater complexity, particularly in the context of audits. We request that this datapoint be included in the NMIG.","E3","E3-4 - Water metrics","17. (c)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Remove parts (a) and (b) and keep the introductory paragraph to avoid unnecessary duplication. Paragraph 5 should read as follows:\n\n\"The undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M.\"","E3","E3 - Objective","5."]
["Excels","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is reasonable to keep the requirement for disclosure of policies targeting sites located in areas with high water risk/stress.\nHowever, we request to specify and clarify below two points; \n 1. Specify an asseeement tool (e.g., Baseline Water Stress in WRI Aqueduct: High = 40–80%, Extremely High = >80%, etc.)\n 2. Clarify to allow that companies can choose their own assessment tools, and the tools, thresholds, and assessment years are sufficient conditions for disclosure","E3","E3-1 - Policies related to water","12."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","This obligation may require breaking down metrics by key sites","E3","E3-4 - Water metrics","AR 2"]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Agree with water withdrawal and water discharge as mandatory KPIs, and with changes of stored water removed.","E3","E3-4 - Water metrics","4."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL: \"If the undertaking has sites located in areas at water risk, including areas of highwater stress that are not covered by its water-related policies, it shall disclose this fact.\"\nThe wording should be crystal clear that it refers to the sites in what the undertaking considers own operations according to ESRS 1 (\"undertaking has sites\") --> Example: E4.14 (E4-2 Policies...) refers to \"sites in its own operations\"","E3","E3-1 - Policies related to water","12."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We support the simplification of the requirement, as this avoids duplication with some overarching requirements in ESRS 2.","E3","E3-3 - Targets related to water","15."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","It is currently unclear how to report the metric related to recycled or reused water. According to the definition, recycled water refers to reuse within the same process, while reused water refers to use in a different process within the same facility or in another facility of the undertaking. This distinction suggests that the two cases should be reported separately, especially since an undertaking may have both types of water reuse. We recommend clarifying whether separate disclosure is required to ensure consistency and comparability across reporting entities.","E3","E3-4 - Water metrics","17. (e)"]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","- Considering disaggregation in location-specific considerations can increase the level of detail required.\n- Reporting at the site level is unacceptable, as it would dramatically increase the reporting burden without providing commensurate value to stakeholders. Such granularity multiplies the volume of datapoints, creates inconsistencies across sites with differing local conditions, and undermines the comparability and usability of disclosures at company level. ","E3","E3 - Objective","9."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"There can be drawn a clear difference between recycled water at intake (ex: municipal recycled water from a common treatment plant), and water recycled at an onsite treatment plant at discharge, and water recirculated through multiple use phases. Different industries (FATP, enclosures, battery) and different business function types (commercial, residential, industrial) have varied ability to make use of these functions based on the nature of the business cycle and capital investment practicalities. It may be beneficial to add these measures so that it’s clear where fit-for-purpose water consumption is occurring, and where onsite conservation / efficiency is occurring from onsite reuse/recirculation. ","E3","E3-4 - Water metrics","14."]
["Excels","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The definition of “water consumption” is unclear. According to the glossary at the end of the standard, water consumption is the amount of water withdrawn on the premises (or site) and not returned to the aquatic environment or third parties during the reporting period. It is therefore not clear how to treat stormwater and meltwater that enter the organisation and are used, in particular whether this water should be included in the calculation of total consumption.\n\nIn addition, a recurring problem in calculating total water consumption under the application requirement (AR 1) to paragraph 17a is that the volume of water withdrawn is often smaller than the volume of wastewater discharged. In such cases, the consumption value would be negative. This also leads to problems in calculating water intensity, since the consumption value would again be negative.","E3","E3-4 - Water metrics","17. (a)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Extension of Delegated Act.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 9"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The  term \"not feasible\" is too subjective, creating significant audit risk. We recommend EFRAG provide further guidance to clarify this threshold.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 10"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I agree","\"sites in its own operations that are in or near a biodiversity sensitive area\" --> simplification questionable as this is still a huge, work-intensive disclosure","E4","E4-2 - Policies related to biodiversity and ecosystems","14 (b)"]
["Excels","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","It is not clear from the presentation of the standard whether paragraph 21 refers only to own operations or whether it also includes the value chain. Since paragraph 21 refers to paragraph 20, which refers to own operations/locations, we assume that this limitation also applies to paragraph 21, but we would prefer a clarification within the standard. ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","21."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I agree","The amendments provide greater clarity on the list of sub-topics covered by the Standards and strengthen alignment with the GRI Biodiversity Standard. This alignment is beneficial as it enhances consistency across reporting frameworks, improves comparability of disclosures, and helps reduce the reporting burden for undertakings using both Standards.","E4","E4 - Objective","4."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","The definition of biodiversity sensitive areas under E4 only partially aligns with GRI’s definition of ecologically sensitive areas, particularly with regard to areas of biodiversity importance. We recommend closer alignment with the definitions used by GRI and TNFD by also including: (i) areas of high ecosystem integrity, (ii) areas of rapid decline in integrity, (iii) areas important for ecosystem service delivery, and (iv) areas of physical water risk. This would ensure greater consistency across standards and improve the relevance of disclosures.","E4","E4-2 - Policies related to biodiversity and ecosystems","14."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I disagree","AR7 allows undertakings to select one of the three types of locations covered by (a), (b), and (c). This option enables undertakings to omit reporting on locations where material impacts occur or could occur. To ensure comprehensive coverage, we recommend revising the text to: “Information to be disclosed under this paragraph applies to locations that meet all of the following criteria (a), (b), and (c).” This change would close potential reporting gap and ensure that disclosures capture all relevant locations.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 7"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","In an attempt to clarify the concept of “near,” the text paradoxically ends up considering as near any site “not inside” a sensitive area. This would effectively imply conducting ad hoc analyses for hundreds of sites (all those not overlapping), in order to identify a science-based buffer based on the ecological specificities of each site. This represents an operational and documentation burden that is entirely disproportionate to the goal of simplification. Moreover, IBAT does not provide a buffer on a scientific basis; it is the user who enters the desired buffer to perform the mapping.\nFinally, it should be noted that ESRS is a disclosure standard, designed to harmonize reporting across companies, not to prescribe detailed operational management of impacts, which is addressed through other regulatory frameworks. The current wording of AR 8 risks turning the standard into a de facto operational requirement, going beyond the intended purpose of ESG disclosure.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","8."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The added para. 14 is not necessary and should be removed as the reference to ESRS 2 GDR-P is sufficient. Otherwise it would differ from the structure of the other ESRS E standards. ","E4","E4-2 - Policies related to biodiversity and ecosystems","14. (b)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","AR 5 for para. 17 should make clear that this is only an information but no disclosure requirement. ","E4","E4-4 - Targets related to biodiversity and ecosystems","AR 5"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I agree",null,"E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 10"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","In the other sections, it is not specified that the impacts are attributed to the company. This difference in wording should be clarified in order to avoid misinterpretation with the previous requirements (10. a-d) ","E4","E4 - Interaction with other ESRS","10. (e)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We recommend integrating the following improvements in wording:\n(a) referring to \"own operations\" instead of \"direct operations\" to avoid any confusion;\n(b) specifying \"where the undertaking has prioritised them…\";\n(c) specifying \"where the assets and/or activities…\".","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 7"]
["Excels","BDO","Auditor","Belgium",null,null,"I partially agree and partially disagree","The current wording remains too generic and lacks practical guidance. It could be beneficial to use similar appoach to generate metrics for ESRS E4 as the approach covered in the TNFD’s metric framework to address location specific aspect of the ESRS E4.  \n\nTNFD provides a clearer, science-based structure with pressure, state, and response indicators, which are more actionable than the broad metric categories currently listed in ESRS E4. (https://tnfd.global/metrics/)","E4","E4-5 - Metrics related to biodiversity and ecosystems change","21."]
["Excels","UNEP-WCMC","NGO","United Kingdom",null,null,"I partially agree and partially disagree","Please clarify whether this AR means that financial institutions do not need to report policies on how they are reducing financed impacts on biodiversity.","E4","E4-2 - Policies related to biodiversity and ecosystems","AR 2"]
["Excels","UNEP-WCMC","NGO","United Kingdom",null,null,"I partially agree and partially disagree","We would recommend clarifying that “(name and type)” means “(name, type of biodiversity-sensitive area and type of impact, risk or opportunity)”.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","20. (b)"]
["Excels","UNEP-WCMC","NGO","United Kingdom",null,null,"I partially agree and partially disagree","Thanks for referencing the buffer zone approach from IBAT. The definition of what ‘near’ means is not clear. We recommend adapting similar language to TNFD’s definition of Areas of influence and referring to  IFC PS6, Good Practices in Collection of Biodiversity Baseline Data, and sector-specific standards, such as GRI Sector Standards or TNFD sector-specific guidance. “Nature-related impacts can arise beyond the immediate site boundary of an activity. Corporates (and financial institutions involved in project finance) should seek to understand areas of influence, noting that the size of the area may vary, depending on the nature of its activities and/or assets, and on the biome, and is often larger than the footprint of the site itself. It includes areas in which there is subject to direct and indirect impacts that may be positive or negative, depending on the site activity. When an organisation's area of influence overlaps with those of other organisations, cumulative impacts should also be considered. A comprehensive approach to outlining a project's area of influence is included in several good practice guidelines, such as IFC Performance Standard 6 and the Good Practices for the Collection of Biodiversity Baseline Data.” ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 8"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","The distinction between a \"transition plan\" and an \"action plan\" remains unclear and has already led to numerous discussions with auditors during the first reporting exercise, even in the case of climate transition plan. Moreover, as previously suggested, we propose to refer to \"consistency\" with relevant global goals, rather than \"to become compatible with\" them.","E4","E4-1 - Transition plan for biodiversity and ecosystems","AR 1"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","Para. 1 states that information on financial effects is expected under [Draft] Amended ESRS E4, which is a valuable acknowledgement given that such information on financial effects is highly decision-relevant, not only for the undertakings themselves, but also for other primary users of their sustainability statements, including those in the financial sector. However, [Draft] Amended ESRS E4 no longer contains specific DRs on financial effects on biodiversity since the former ESRS E4-6 is proposed to be removed. Financial effects are also not included in any other disclosure requirements in ESRS E4, which makes this statement somewhat void. Since nature-related financial effects can be substantial, the standards should ensure that they are considered in reporting on actual and anticipated financial effects under ESRS 2 SBM-3. If it proofs difficult to reinstate them as part of ESRS 2, they should at the least be included in the non-mandatory guidance.","E4","E4 - Objective","1."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","ESRS E4 para. 10 is rather confusing: it states that climate change and pollution are covered only in E1/E2, but sub-points a–d indicate their impacts are addressed in E4. To avoid confusion, we recommend clarifying that ESRS E1 and E2 cover the drivers of climate change and pollution themselves, while ESRS E4 addresses their specific impacts on biodiversity and ecosystems. We suggest to modify the text of para. 10 in the following: delete \"these drivers are covered in this Standard, except for\", so that it reads \"...alien species. Climate change and pollution are mainly addressed by [Draft] Amended ESRS E1 Climate Change and [Draft] Amended ESRS E2 Pollution. The main points of interaction…”","E4","E4 - Interaction with other ESRS","10."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","Acronyms: the acronym list should include “GBF” – Global Biodiversity Framework since this abbreviation is used in ESRS E4, but not introduced before","E4","E4-1 - Transition plan for biodiversity and ecosystems","AR 1"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I agree","We support the decision of EFRAG to maintain the concept of biodiversity-sensitive areas, since we also consider this location-specific information as highly decision-useful. It provides essential insights into impacts, risks and opportunities that cannot be captured through aggregated reporting alone. Even though E4-5 has lost in topical granularity, we generally welcome that [Draft] Amended ESRS E4-5 now foresees the mandatory disclosure of metrics related to material impacts on biodiversity and ecosystems. ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","21."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","While E4-3 and E4-4 introduce transparency requirements for biodiversity offsets, they remain significantly less detailed and prescriptive than the new E1-9 provisions on carbon removals and carbon credits. To ensure alignment and coherence across ESRS topical standards, and to avoid the biodiversity offset requirements being perceived as weaker than climate-related offset requirements, we recommend that EFRAG:\n• Provide a clear definition of “biodiversity offset” and distinguish it from general conservation or restoration actions.\n• Mirror E1’s structure by separating disclosure of internal offsetting projects from offsets purchased or financed externally.\n• Require minimum integrity criteria similar to those for carbon credits, covering ecological quality factors.\n• Require reference to recognised quality standards (or state explicitly if none exists).\n• Mandate disclosure of the proportion of targets met through offsets versus direct biodiversity actions.","E4","E4-3 - Actions and resources related to biodiversity and ecosystems","16."]
["Excels","Nature Positive Initiative Secretariat","NGO","United States",null,null,"I partially agree and partially disagree","We support the alignment with  the draft global consensus metrics on state of nature, convened by the Nature Positive Initiative. \nRemoval of the metric specifications from the mandatory requirements is particularly problematic for biodiversity and ecosystems metrics, where standardisation is more limited at present than with other metrics. Specifying metrics (as is now in NMIG 18-20) would give companies the information they need to select and report practical, credible and comparable metrics.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","21."]
["Excels","Nature Positive Initiative Secretariat","NGO","United States",null,null,"I disagree","Between site level measurement and estimation must be an additional step in the hierarchy: using national or global data layers. With the increasing availability of higher-quality remote sensing data, this is now more feasible and more accurate for measuring state of nature. It provides a much more accessible means of reporting for companies. Estimations should be the third resort.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 10"]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","In the other sections, it is not specified that the impacts are attributed to the company. This difference in wording should be clarified in order to avoid misinterpretation with the previous requirements (10. a-d).","E4","E4 - Interaction with other ESRS","10. (e)"]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","We support the objective of requirement 20 to enhance transparency on biodiversity-related impacts, risks and opportunities. Nevertheless, its current wording could be misinterpreted as requiring large multinational undertakings to enumerate every location with a material impact — an effort that may be disproportionate and obscure the most decision-useful information. We suggest clarifying that this is not the intent and allowing aggregation (e.g., disclosure of the most significant or representative locations, or grouping by geography, ecosystem type or business segment) so reporting remains both meaningful and practicable. ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","5."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","to be added \" when applicable\" ","E4","E4-2 - Policies related to biodiversity and ecosystems","14. (b)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nWhen reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS E4 Biodiversity , when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, and targets (if in place),  dependencies when relevant, metrics and financial effects\nSuggestion:\nWhen reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS E4 Biodiversity, when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, metrics and targets (if in place), dependencies when relevant, metrics and financial effects.","E4","ESRS E4 - Objective","1."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","This requirement was moved from IRO-1, which is welcomed. However (within IRO-1) it should be clarified that for sectors where it is not to be excpected that there are own sites of an undertaking with material IROs reg. biodiversity (e.g., withtin the financial services sector), no detailed analysis of all sites of the undertaking is required as part of the DMA.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","20."]
["Excels","Allianz SE","Insurance","Germany",null,null,"I disagree","Additional metric requirement. Although \"ecosystem services\" is mentioned in the delegated act in several instances, it is not a metric requirement in the delegated act.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 9"]
["Excels","Taskforce on Nature-related Financial Disclosures","Standard setting initiative","United Kingdom",null,null,"I partially agree and partially disagree","The disclosure of dependencies has been further weakened (to ‘when relevant’) in the new paragraph 1. \nThe TNFD suggests to remove the specification ‘when relevant’ in paragraph 1 and reinstate, either at the level of ESRS 2 or at the level of the individual topical standard, a similar text to the Set 1 paragraphs, such as the one asking for disclosure of ‘the nature, type and extent of the undertaking’s material (…) dependencies (…) related to [biodiversity and ecosystems], and how the undertaking manages them’.","E4","E4 - Objective","1."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","This is highly relevant, but in the DASB view, the impact is negated because it will only be reported by companies large enough to fall under the ESRS. DASB imagines some might have a significant impact on their surroundings (in the Dutch context, exceeding local, municipal, and even provincial environmental regulations), yet are still too small to fall under the CSRD. As a result, this ultimately provides neither control nor insight.","E4","E4-4 - Targets related to biodiversity and ecosystems","20."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Target setting is part of the LEAP approach that is performed, good to make this clear with a link to the LEAP approach,  mentioned in ESRS 2 AR 22 for para 26, so that also the TNFD guidance for target can/will be used as a basis and as part of the LEAP approach. Adding this reference will increase quality of target setting. ","E4","E4-4 - Targets related to biodiversity and ecosystems","AR 5"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The IBAT Alliance licences commercial access to the IBAT platform. I think there shouldn't be a reference to a commercial plattform in a EU regulation. ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 8"]
["Excels","Little Blue Research","Consultant (including software vendor)","United Kingdom",null,null,"I partially agree and partially disagree","Missing dependencies","E4","E4-5 - Metrics related to biodiversity and ecosystems change","19."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","Using \"objective” in this sentence is confusing, since the objective of the standard is already introduced in para. 2. Delete \"The objective of\" and start with \"This Standard shall…\"","E4","E4 - Objective","8."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","Disclosure under ESRS E4-1 should be mandatory whenever a transition plan exists („if… has in place“). The additional condition of publication (“and has made public”) should be deleted. This condition would set incentives for non-disclosure and lead to a duplication of published information, which should both be avoided. If EFRAG were to delete the condition of publication, users would also understand that non-disclosure according to E4-1 indicates the absence of a transition plan, which is considered a relevant information in itself.","E4","E4-1 - Transition plan for biodiversity and ecosystems","12."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","Include \"freshwater ecosystems\" in item (c)","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 9"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The criteria identified in letter a), b), c) seems to require the disclosure on all the location with IRO + all the sites prioritised internally + the assets (and is not clear why we are not referring anymore to locations) with negative interactions with biodiversity areas. The interaction of the 3 points could lead to a ling ist of location to disclose. It should be clarified that the intention is not to require disclosure for every single site, but rather a limited number of representative sites selected according to prioritisation criteria defined by the company ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 7"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","In an attempt to clarify the concept of “near,” the text paradoxically ends up considering as near any site “not inside” a sensitive area. This would effectively imply conducting ad hoc analyses for hundreds of sites (all those not overlapping), in order to identify a science-based buffer based on the ecological specificities of each site. This represents an operational and documentation burden that is entirely disproportionate to the goal of simplification. Moreover, IBAT does not provide a buffer on a scientific basis; it is the user who enters the desired buffer to perform the mapping.\nFinally, it should be noted that ESRS is a disclosure standard, designed to harmonize reporting across companies, not to prescribe detailed operational management of impacts, which is addressed through other regulatory frameworks. The current wording of AR 8 risks turning the standard into a de facto operational requirement, going beyond the intended purpose of ESG disclosure","E4","E4-5 - Metrics related to biodiversity and ecosystems change","8."]
["Excels","SAIM GmbH","Consultant (including software vendor)","Germany",null,null,"I agree","The further clarification of interactions between E4 and other standards was much needed and we agree with it. This has been a constant topic in our discussions with clients.","E4","E4 - Interaction with other ESRS","10."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Amended ESRS E4 introduces a requirement for undertakings to disclose biodiversity transition plan features when such plans exist and are public. As users of transition plans, AFME supports the disclosure of transition plans on a voluntary basis if an entity has one (as with E1). \nAFME does not support the mandatory disclosure of biodiversity transition plans, and EFRAG should clarify that such disclosures are voluntary and subject to an entity’s materiality assessment. While framed as conditional (\"if the undertaking has in place\"), there is a risk that this requirement could create an expectation that organisations must develop biodiversity transition plans aligned with the Kunming-Montreal Global Biodiversity Framework. \nIn addition, climate transition plans disclosed under E1 may reference nature/biodiversity and include biodiversity-related metrics but would not be considered a standalone “transition plan” for biodiversity and ecosystems. It is unclear how organisations who integrate nature and biodiversity into their existing transition planning would meet this new E4 disclosure requirement. ","E4","E4-1 - Transition plan for biodiversity and ecosystems","AR 1"]
["Excels","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We request to clarify the cliteria of “material impacts, risks and opportunities” for disclosure.\nThere is concern that each companies has defferent interpretation of this criteria.It should be discussed.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","20. (a)"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","While this requirement can be useful, it might create additional burden","E4","E4-4 - Targets related to biodiversity and ecosystems","AR 6"]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","The notion of “transition plan” is not yet clearly defined. Companies are currently exploring the best ways to develop action plans on this highly complex subject, whether through national or international initiatives, but no official certification of such analyses and plans exists to date. Making this datapoint mandatory, even with precautions (i.e. if the company has a transition plan and has published it), would discourage companies from taking initiatives, as it would trigger compulsory verification by auditors without existing auditing standards. Furthermore, \"so it is aligned\" with the Global Biodiversity Framework (GBF) lacks clarity. It would be more appropriate to refer instead to \"consistency\" with the objectives of the GBF.","E4","E4-1 - Transition plan for biodiversity and ecosystems","12."]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","The distinction between a \"transition plan\" and an \"action plan\" remains unclear and has already led to numerous discussions with auditors during the first reporting exercise, even in the case of climate transition plan. Moreover, as previously suggested, we propose to refer to \"consistency\" with relevant global goals, rather than \"to become compatible with\" them.","E4","E4-1 - Transition plan for biodiversity and ecosystems","AR 1"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","The AR makes prejudging assumptions for the DMA which contradict the DMA principles. The AR suggests the worst case if the site is in a biodiversity sensitive area \"is highly likely that its activities will negatively affect the area\" We doubt, this assumption should be taken without the DMA.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 8"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","The IBAT Alliance licences commercial access to the IBAT platform. There shouldn't be a reference to a commercial plattform in a EU regulation. ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 8"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","N.a.","E4","E4-2 - Policies related to biodiversity and ecosystems","13."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","N.a.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","19."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","AR 8 should make clear that IBAT is only one of many different tools to examine biodiversity sensitive areas. ","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 8"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","In the objectives section, paragraph 9 the log of amendments states that the topic of sites is addressed in both ESRS 1 and ESRS 2. This objective paragraph only mentions ESRS 1. It should also reference the relevant paragraph in ESRS 2.","E4","General disclosures ",""]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","A definition should be included for biodiversity offsets ","E4","E4-3 - Actions and resources related to biodiversity and ecosystems","16."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Issues with lack of clarity of “biodiversity sensitive areas” definition ","E4","Annex II","NA"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Compatibility with the Kunming-Montreal Global Biodiversity Framework raises practical challenges: no standardised methodology exists at corporate level, impacts are localised, and sector-specific metrics are under development. Companies should be allowed to present a plan even if not fully compatible, provided they disclose the current level of alignment and measures planned to achieve it.  The current contradiction between references to “alignment” in the main body and “compatibility” in the application requirements should be resolved by retaining “compatibility,” consistent with E1.","E4","E4-1 - Transition plan for biodiversity and ecosystems","12."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Clarify that metrics on biodiversity may be \"on own operations and when relevant on the value chain\" (to be added at the end of the §21.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","21."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","N.a.","E4","E4-2 - Policies related to biodiversity and ecosystems","13."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","AR 3 for para. 13 should be removed as it only adds irrelevant additional information. At least please make clear that AR 3 does not require a “not applicable” disclosure. ","E4","E4-2 - Policies related to biodiversity and ecosystems","AR 3"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","AR 5 for para. 17 should make clear that this is only an information but no disclosure requirement. ","E4","E4-4 - Targets related to biodiversity and ecosystems","AR 5"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Para. 20 should only refer to impacts. The locations shall only be reported if there are significant and verifiable negative impacts affecting biodiversity sensitive areas. A general reporting of locations should be avoided as there is no added value.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 7"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The  term \"not feasible\" is too subjective, creating significant audit risk. We recommend EFRAG provide further guidance to clarify this threshold.","E4","E4-5 - Metrics related to biodiversity and ecosystems change","AR 10"]
["Excels","Reclaim Finance","NGO","France",null,null,"I partially agree and partially disagree","The AR lacks references to methodologies and frameworks that could guide companies (including SBTN, TNFD, Forest500…).","E4","E4-1 - Transition plan for biodiversity and ecosystems","AR 1"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Disproportionate cost. To be simplified.","E5","E5-5 - Resource outflows","19."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","'total weight of critical and strategic raw materials' not meaningful; very high data collection efforts necessary, especially for critical/strategic raw materials that are/might be included in other products","E5","E5-4 - Resource Inflows","15. (c)"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I disagree","Reference seems wrong, the Eco-design for Sustainable Products Regulation has got the identifier (EU) 2024/1781 (Ökodesign-Verordnung für nachhaltige Produkte)","E5","E5-1 - Policies related to resource use and circular economy","BFC 388"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I partially agree and partially disagree","Additional requirement\nBfC (130): Als Erleichterung gedacht, \"not forcing undertakings to make unreasonable estimations but instead allowing them to disclose on the figures they have and can reasonably document.\"","E5","E5-5 - Resource outflows","18 (e)"]
["Excels","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Clarification needed: Wording should be harmonized across different EU standards/methods, e.g. PEFCR. This DR should aim for the \"recyclability\" of the whole product (e.g. as defined by PEFCR with recyclability disruptors\") as opposed to recyclability of individual materials within the product. It is decisive how the final product is assembled, which requires a consideration of more aspects rather than just materials. Currently the wording is misleading.\n\nAdditional clarification needed: is \"rate of\"  the same as \"share of\"?","E5","E5-5 - Resource outflows","17. (c)"]
["Excels","Materiality","Consultant (including software vendor)","Poland",null,null,"I disagree","Par. 15 d) is inconsistent regarding requirement of disclosing \"recycled materials used\". Annex II neither defines \"recycled materials\" nor  \"recycling\". Annex II defines only \"secondary resources\" as \"materials previously used (secondary) and that are recovered from waste streams and reintroduced into production cycles, reducing reliance on primary resources and minimizing environmental impact.\" For clarity, \"recycled materials\" should be defind and included in \"secondary resources\" definition.","E5","E5-4 - Resource Inflows","15. (d)"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","In the Log of Amendments, it is stated \"Definitions added to the Annex II: circularity and eco-design\". While the definition of eco-design exists in Annex II, the definition of 'circularity' is missing. We suggest clarifying whether 'circularity' refers to the definition of 'circular economy'.","E5","E5-1 - Policies related to resource use and circular economy","11."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We propose aligning the Annex II definition of 'recovery' with GRI 306's definition: \"operation wherein products, components of products, or materials that have become waste are prepared to fulfill a purpose in place of new products, components, or materials that would otherwise have been used for that purpose. Source: United Nations Environment Programme (UNEP), Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, 1989; modified. Examples: preparation for reuse, recycling. Note: In the context of waste reporting, recovery operations do not include energy recovery.\"","E5","E5-5 - Resource outflows","18. (c)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Disclosure should be limited not only to key materials (already in the current Draft) but also key products (new suggestion for reducing the reporting burden while maintaining a comprehensible level of disclosure; also in line with E5-5 Resource Outflws where this focus is implemented in the current Draft). Further proposed simplification: omission of e.g. clippings/scrap (for manufacturing companies). Nevertheless, Good focus on „secondary resourced materials”. \nNo mention anymore of reused and recycled materials/ components and packaging. ","E5","E5-4 - Resource Inflows","15. (d)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Significant improvement, as the example makes it clearer what level of detail is required here.","E5","E5-5 - Resource outflows","AR 5"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","In the current standard, it is clear that E5 related activities also interact with workers of the value chain (ESRS S2) : \"\"E5 related activities often involve intensive resource extraction, manufacturing, or waste processing, which can expose workers to hazardous conditions and low-wage labour, especially in lower tiers of the value chain\". We recommend maintaining such interaction in the revised E5. This could be done in the NMIG.","E5","E5 - Interaction with other ESRS","9. (e)"]
["Excels","UPM-Kymmene Corporation","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","We are not 100% sure that it is not anymore required to disclose the amounts of each pollutant above the threshold from Annex II of the Industrial Emissions Portal Regulation. This is due to possible different interpretation of \"The pollutants TO BE CONSIDERED for reporting ...\" in AR 2. Please clarify or re-formulate \"to be considered\" in the application requirement.","E2","E2-4 - Pollution of air, water and soil","AR 2"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Clearer guidance from EFRAG on the level of granularity of the key material clusters needed (especially for comparability). E.g. Packaging material vs. Glas/metal/paper/plastics split of packaging material. ","E5","E5-4 - Resource Inflows","15. (a)"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","\"Preparation for reuse\" does not correspond to any of the R/D codes of  the Waste framework directive. This information should be retained only in the narrative part. In the future French translation of this standard, the title should be corrected to refer to \"réutilisation\" rather than \"réemploi\".","E5","E5-5 - Resource outflows","18. (c)"]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","Please consider the following proposals for ESRS E5-related terms and definitions:\n- Generally, we recommend to cross-check all definitions with the terminology from ISO 59004:2024 “Circular economy — Vocabulary, principles and guidance for implementation” and relevant legislation. \n- \"resources“ is used frequently in the, but not defined. It should be clarified in a separate definition that “resources” means “material resources” in the ESRS, not natural resources more broadly, nor financial nor human resources. This would help to clarify and be in line with how The International Resource Panel at UNEP is using the term. \n- “Circular economy principles” is used inconsistently and should be aligned with common frameworks such as 10R or Narrow/Slow/Close/Substitute. \n- \"circular material use rate” is defined but not used in the standard. The definition is also unclear because it does not define “circular material use” and does not link to the definition of “secondary resources”. It should be deleted.\n","E5","E5 - Objective","1."]
["Excels","German Environment Agency","National supervisory authority & regulator","Germany",null,null,"I partially agree and partially disagree","The definition of \"ecodesign\" should be aligned with the definition in the the ESPR: \"‘ecodesign’ means the integration of environmental sustainability considerations into the characteristics of a product and the processes taking place throughout the product’s value chain;\"","E5","E5-1 - Policies related to resource use and circular economy","11."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","It is suggested to clarify that this DR applies only to companies that are subject to the  CRM Act: \"the percentage of total weight of critical and strategic raw materials, whenever the undertaking is required to assess those material flows according to the CRM Act regulations\".","E5","E5-4 - Resource Inflows","15. (c)"]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","Para 18 e requires to disclose \" the percentage and/or total weight for which the final destination is unknown.\"  \nWe believe there is limited usefulness of a “final destination unknown” metric. Disclosing the percentage or total weight of materials with unknown final destinations could generate significant reporting effort with limited value for stakeholders, particularly if large portions are unknown. Suggestion to move this paragraph to voluntary and focusing on qualitative information, or allowing aggregation of “unknown” categories with explanation of materiality and mitigation efforts (if material).","E5","E5-5 - Resource outflows","18. (e)"]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","The new paragraph 15(a) specifies that the entity discloses \"the key materials used to manufacture products, deliver them, and/or provide services.\" In our opinion, it is unclear what information the entity is expected to provide here. Is this intended to describe all materials, substances, and products entering the organization's operations or value chain for production, consumption, maintenance, or service provision that the entity considers significant (with respect to the definition of inputs)? Or was the intention to present key materials broken down into categories identified in the definition of key materials, such as: plastic, plastic-metal composite, colored fabrics, solvents, wood, fabrics or fibers, glass, foam, adhesives, and finishes.","E5","E5-4 - Resource Inflows","15. (a)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree"," Please note that Annex II specifically mention to all materials, substances, and products; however, apparently, it does not encompass services.","E5","E5 - Objective","4. (b)"]
["Excels","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We reject this new data point on the disclosure of critical and strategic materials, as this is sensitive information that we will not publish. ","E5","E5-4 - Resource Inflows","15. (c)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I disagree","Par. 15 d) is inconsistent regarding requirement of disclosing \"recycled materials used\". Annex II neither defines \"recycled materials\" nor  \"recycling\". Annex II defines only \"secondary resources\" as \"materials previously used (secondary) and that are recovered from waste streams and reintroduced into production cycles, reducing reliance on primary resources and minimizing environmental impact.\" For clarity, \"recycled materials\" should be defind and included in \"secondary resources\" definition.","E5","E5-4 - Resource Inflows","15. (d)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Please note that this comment relates to the objective - paragraph 6 references to a disclosure objective of each DR, but I think this should be removed (also saw this in other E-standards)","E5","E5-1 - Policies related to resource use and circular economy","10."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","- Too  granular, data currently not available and disproportionate costs. Data retrieval is very difficult since operators involved in disposal-related activities often are not direct partners of the company generating waste.\n- Reporting information on the value chain activities will be difficult for the first years and we suggest to qualify this information as qualitative or to consider adopting a phase-in approach.","E5","E5-5 - Resource outflows","18. (d)"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Companies that do not use radioactive substances in their production processes should not be required to report them. Exceptions should be introduced for laboratory applications, measuring instruments, markers, naturally occurring radioactive materials, and activities below the exemption threshold of radiation protection legislation, in order to avoid the effort of reporting insignificant quantities and negligible exposures.","E5","E5-5 - Resource outflows","19."]
["Excels","German Federal Agency for Nature Conservation (BfN)","Public authority","Germany",null,null,"I partially agree and partially disagree","Further on definitions: \n- The new definition for “resource efficiency” introduces the term “material consumption” which is not explained. Instead, the definition should refer to the already defined term “resource inflow”. We also not that resource efficiency is not used in E5.\n- The new definition for “secondary resources” misses the fact that those resources can also come from non-waste streams, e.g. by-products such as metallurgical slags. Hence, it should be amended to \"waste and non-waste streams\" \n- “sustainably sourced” is referring only to the assessment of direct suppliers. It is not in line with the OECD Guidelines for Multinational Enterprises for Responsible Business Conduct. Moreover, the term is not correctly used in the standard. The definition should either be removed or fundamentally revised. If our proposal to amend the set of metrics is adopted, the definition would not be needed anymore.\n","E5","E5 - Objective","1."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Disclosure should be limited not only to key materials (already in the current Draft) but also \"key products and services\" (new suggestion for reducing the reporting burden while maintaining a comprehensible level of disclosure)","E5","E5-4 - Resource Inflows","15."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is suggested to clarify that this DR applies only to companies that are subject to the  CRM Act: \"the percentage of total weight of critical and strategic raw materials, whenever the undertaking is required to assess those material flows according to the CRM Act regulations\".","E5","E5-4 - Resource Inflows","15. (c)"]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","“Recyclable” and “Recycled” materials are not specifically defined; it is unclear whether the definitions of “Recycling” are to be considered in this context.","E5","E5-5 - Resource outflows","18."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","In the definition of key materials, the phrase \"(can be sourced 'as is' or be assembled in goods and substances purchased)\" should be deleted to clarify that it refers only to materials and not to prefabricated components/assemblies","E5","E5-4 - Resource Inflows","15."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This is difficult to answer without burdening the supply chain with information about preliminary products. It should be possible to use standard values/average values here. ","E5","E5-4 - Resource Inflows","15. (d)"]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","\"Preparation for reuse\" does not correspond to any of the R/D codes of  the Waste framework directive. This information should be retained only in the narrative part. In the future French translation of this standard, the title should be corrected to refer to \"réutilisation\" rather than \"réemploi\". Issuers that are not producers should be exempted from this requirement if no public database are available.","E5","E5-5 - Resource outflows","18. (c)"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","Good focus on „secondary resourced materials”. \nNo mention anymore of reused and recycled materials/ components and packaging. \n","E5","E5-4 - Resource Inflows","15. (d)"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","Good definition of biological materials and focus of percentage with sustainably sourced materials on total weight of key biological materials.","E5","E5-4 - Resource Inflows","15. (e)"]
["Excels","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","(We basically recommend deleting DR 18(a–c) on waste for the reasons stated in E5-5.)\nThere is a requirement to disclose recyclability, but the definition is unclear.","E5","E5-5 - Resource outflows","17. (c)"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","This streamlines the process by no longer considering the value chain. However, this now requires more disclosures. More clarification is needed for \"key materials\".","E5","E5-4 - Resource Inflows","15."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The process is now streamlined as only \"key\" products are required. However, more clarity is needed for the wording \"key\"","E5","E5-5 - Resource outflows","17."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I disagree","Clarity is needed on whether estimations are allowed or not when classifying the waste, in cases where no primary data is available. Should it be the case, such an approach would be inconsistent with ESRS 1 and ESRS 2 standards. This requirement should be removed or reformulated to be made optional.","E5","E5-5 - Resource outflows","18. (e)"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","It should be clarified if retail companies are intended to be included in the scope of this requirement.","E5","E5-4 - Resource Inflows","15."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","RED FLAG: According to BfC 379 this is meant to be a clarification. However, we note two stages of the value chain are mixed together. Para 17(d) of the ED addresses “rate of recycled material used in key products “, and it relates to resource outflows. This datapoint is not in the delegated act, so it is a new datapoint (a disclosure on the recycled content in products is not required in the delegated act). At the same time, it is proposed to amend 31(c) in resource inflows (“the weight … of secondary reused or recycled components …) to require disclosing “secondary resourced materials” in ED E5.15(d), which leaves it to the undertaking to understand the difference – if any – to current 31(c). Furthermore, the new datapoint in ED E5.17d will result in additional burden.","E5","E5-5 - Resource outflows","17. (d)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We understand the rationale for the proposed datapoint 15(c) is to align with the EU Critical Raw Materials Act (CRMA). However, we have significant concerns about the practicality (tracking all raw materials in complex value chains) and decision-usefulness of this metric. Disclosure should be limited not only to key materials (already in the current Draft) but also key products (new suggestion for reducing the reporting burden while maintaining a comprehensible level of disclosure; also in line with E5-5 Resource Outflws where this focus is implemented in the current Draft). Further proposed simplification: omission of the datapoint for critical and strategic raw material (for manufacturing companies). This new datapoint requires companies to disclose sensitive information which may lead to competitive disadvantages; should hence be a \"may\"-disclosure; further it increases burden on the disclosing companies in gathering these information.","E5","E5-4 - Resource Inflows","15. (c)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","This new requirement would entail additional work if this case were to arise.","E5","E5-5 - Resource outflows","18. (e)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","The newly introduced definition of key materials leaves room for differences in interpretation which could hinder comparability. To mitigate this, EFRAG should provide guidance in the NMIG for determining materials that meet the criteria for \"key materials.\" ","E5","E5-4 - Resource Inflows","15. (a)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","The total weight of key materials has been amended to include a breakdown. This breakdown is an improvement as it will allow companies to compare materials that are similar in nature. On the other hand,  this update will create additional work for companies that already report as they will now need to tag each type of key material for the breakdown. ","E5","E5-4 - Resource Inflows","15. (b)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","The glossary should include a definition for sustainably sourced ","E5","E5-4 - Resource Inflows","15. (e)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Addition on making the reference to key material introduced: Disclosing key raw materials and their exact weights per key material - involves sensitive information and may be misinterpreted as shrinkflation, despite resulting from more efficient material use.","E5","E5-4 - Resource Inflows","15. (b)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","It adds value to have weight diverted to disposal as a sub-metric in percentage and weight. Yet, it is not clear if it refers to waste 'send-to' e.g. recycling or to 'mass-balance' approach e.g. materials recovered through recycling. Additional guidance would support uniformity.","E5","E5-5 - Resource outflows","18. (c)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Introduce the reference to marine resources, ensuring that material IROs related to them can be addressed through entity-specific disclosures under ESRS E5. In line with the principle on location-specific considerations in ESRS E4 §9, we propose introducing a corresponding principle on marine resources.\n\nProposed wording:\n\"Marine resources should be considered when they are relevant to the undertaking’s strategy and business model. Where material IROs arise in relation to marine resources, it is important to consider appropriate entity-specific information in accordance with ESRS 1, paragraph 11.\"","E5","E5 - Objective","1."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Delete the datapoint on “recycled materials used in key products” and retain only the one on “recyclable materials included in key products and their packaging”. This ensures consistency with the focus on outflow metrics (product characteristics) rather than inflow metrics (use of recycled inputs)","E5","E5-5 - Resource outflows","17. (d)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","We suggest to remove wording in brackets (“including mineral and biotic marine resources”) and incorporate it either in the Application Requirements or in the term “resources inflows” defined in the glossary in Annex II.  The specific focus on “marine resources” could create confusion and imply a stronger focus on one resource/ecosystem whereas the definition is larger.","E5","E5 - Objective","4. (a)"]
["Excels","Dragerwerk AG &Co.KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","This information is almost impossible to determine with certainty. Metals, for example, usually contain an unknown recycled content. As a single figure, the information is also useless.","E5","E5-5 - Resource outflows","17. (d)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","Focus on key products helps to disclose relevant information for stakeholders while reducing the burden for disclosing companies","E5","E5-5 - Resource outflows","17. (b)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","This is a resource intensive exercise to calculate and it is not clear what the benefit is of reporting the total weight of key materials used.","E5","E5-4 - Resource Inflows","15. (b)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,null," The disclosure requirements should be aligned with the Waste Framework Directive, the Packaging and Packaging Waste Regulation (PPWR) and the WEEE Directive, which is currently under revision.                                                                                                                                                                                                Change to: The undertaking shall disclose the following information on waste streams that are linked to a material impact, risk or opportunity from its own operations: ) a description of the material waste streams relevant to its sector or own activities (identified through the DMA process)\"","E5","E5-5 - Resource outflows","18."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"These disclosure requirements should be closely aligned with existing ecodesign regulations (ESPR) and underlying standards (EN 4555X) which define durability, reparability, recyclability and recycled content. ","E5","E5-4 - Resource Inflows","16."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Disclosure of the recycling material usage rate has been added, but this is almost the same as the disclosure of secondary resourced materials in Inflow 15(d), resulting in duplication. Therefore, only one of the two should be disclosed.","E5","E5-5 - Resource outflows","17. (d)"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","This indicator shall not be compulsory as it can induce to add waste which have no coherence and as such may false the interpration of the reality. This paragraph could be deleted.","E5","E5-5 - Resource outflows","18. (b)"]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I partially agree and partially disagree","In principle, the BAK welcomes the restructuring into topics and companies (no more sub-subtopics) for better alignment with management processes as well as a more comprehensible presentation of the materiality analysis and the IROs (Impact Risks Opportunities).\nHowever, in the objectives for S 1 (page 3 of the \"Log of Amendments S 1\"), it was clarified that a company only has to report on the sub-topics \"own workforce\" (S1-5), \"non-employees S1-6) and \"remuneration parameters\" (S1-16) if the company comes to the conclusion that its own workforce is material. We are of the opinion that the interests of the company's own workforce are generally to be regarded as material in every company and that this information should therefore not be subject to the materiality reservation. The CSRD has also specified in detail the social concerns to be reported in Article 29b – which forms the basis for the ESRS.","S1","S1 - Objective","3."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I agree","The envisaged definitions for the different employment groups increases the clarity and comparability of reporting.","S1","S1 - Objective","9."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I partially agree and partially disagree","The BAK criticises the lack of definition of RTD in the present ED. In the interests of comparability, transparency and simplification for reporting, the BAK calls for a uniform definition of the term FTE to be included in the ESRS.\nCompared to the current ESRS, there is no longer any provision of explanations to understand the fluctuation rate. From the BAK's point of view, fluctuation is a central social indicator and therefore a statement on the development of fluctuation rates should be disclosed.","S1","S1-5 - Characteristics of the undertaking’s employees","23. (d)"]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I agree","The BAK welcomes the transfer from the CSRD to the involvement of the employee representatives and forwarding their opinion to the supervisory bodies. This is a significant step forward \ntransparency and stakeholder involvement and represents a significant improvement for clear reporting.","S1","S1-3 - Actions and Resources related to Own workforce","AR 11"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","simplification edit, thanks for the examples in brackets - better move to ESRS 2 ","S1","S1-1 - Policies related to Own workforce","11."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We offer paternity leave in every operation. Both maternity leave and paternity leave are key to our work-life balance commitment.","S1","S1-10 - Social protection","34. (d)"]
["Excels","BDEW","Other - please specify (required)","Germany",null,null,"I agree","- Feedback to EFRAG for V 1.5: \"In the ESRS Set 1 depending on the standard “incidents” meant different things.\"; if it is about the complaints filed through channels it should state that/ if it is about actual confirmed incidents, it should also state that\n- nevertheless \"Incident\" is a defined term, which should be specified.","S1","S1-16 - Incidents of discrimination and other human rights incidents",""]
["Excels","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","There may be countries outside the EU that apply a minimum wage which, however, does not fully cover the ILO wage-setting principles (particularly the aspect of tripartite social dialogue). Does the incomplete consideration of all ILO wage-setting principles lead to a mandatory exclusion of the data point wage applied in these countries from the reporting? ","S1","S1-9 - Adequate wages","32."]
["Excels","Otto Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","AR 27 states that the company should use definitions for work-related injuries according to the national laws of the countries. However, AR 29 on work-related illnesses does not mention this. Shouldn't the company use the definitions according to the national laws of the countries to determine the type of work-related illness too?","S1","S1-13 - Health and Safety metrics","AR 29"]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I disagree","Disagree with the arbitrary removal of age. Age a known discrimination factor in workplaces and managing risks and impacts related to demographic developments requires access to data. Suggest to reinstate former requirement S1 66 (b) on the distribution of employees by age group. ","S1","S1-8 - Diversity metrics","30."]
["Excels","European Transport Workers' Federation (ETF)","Trade union","Belgium",null,null,"I partially agree and partially disagree","Datapoint on workers actually taking family-related leave should be reinstated","S1","S1-14 - Work-life balance metrics","42."]
["Excels","GKK Partners","Consultant (including software vendor)","Germany",null,null,"I disagree","Unclear why \"existing\" definition \"10% threshold\" is changed to \"ten largest countries\". \nThis constitutes a more complex way.\nFurthermore, it can be expected that the \"10% threshold\" is available within undertaking's data.","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","23. (a)"]
["Excels","GKK Partners","Consultant (including software vendor)","Germany",null,null,"I disagree","Table 2: is the connection to corresponding adjustment of \"10 % threshold\" (see line 1) clear enough?\nAs outlined above, \"10% threshold\" preferred and suggested. ","S1","S1-5 - Characteristics of the undertaking’s employees","AR 11"]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","(27 b and 28 a) added references which total number of employees to consider > removes any uncertainty","S1","S1-7 - Collective bargaining coverage and social dialogue","27. (b)"]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","(33) no further guidance is provided on scope and how to disclose in case of local specifics (for example: in different countries eligibility for such protection might depend on type of employees, i.e temporary or and hourly paid employees). For global companies reporting burden remains > further guidance is needed","S1","S1-10 - Social protection","33."]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","S1-16 (AR 41) good clarification no cross-reference or reconciliation to financial statements is required.","S1","S1-16 - Incidents of discrimination and other human rights incidents","AR 41"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","DR S1-8 on diversity has been reduced to just reporting gender diversity at the top management level. We deem it important to reinstate former requirement S1 66 (b) on the distribution of employees by age group to provide additional information about the diversity among employees and as important contextual information on potential impacts. This also supports alignment with GRI 405-1-b-ii. However, to support simplification, each organization could define its own specific age groups, as suggested in the latest GRI Diversity and Inclusion exposure draft (available for public consultation until 15 September), since different age groups may be relevant depending on the organization’s specific characteristics, such as its sector of operation.","S1","S1-8 - Diversity metrics","30."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We recommend retaining parental leave and retirement (former S1 74 (d) and (e)), as two important areas of social protection. GRI's Remuneration and Working Time exposure draft, which was available for public consultation in 2024, includes both maternity and paternity leave in the context of social protection: \"Maternity and paternity benefits in case of pregnancy or childbirth – covers income security, maternal healthcare, maternity leave, paternity leave, parental leave, adoption leave, breastfeeding arrangements, employment protection, and childcare solutions after return to work.\"","S1","S1-10 - Social protection","34."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We recommend retaining the following former guidance from AR 94 within new AR29: \"the disclosure may include cases of work-related ill health that were detected during the reporting period among people who were formerly in the undertaking’s workforce.\"","S1","S1-13 - Health and Safety metrics","AR 29"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The paragaph does not support the aim of simplifying the ESRS. This paragraph generates considerable additional work in reporting and additional coordination requirements (e.g. determining and adjusting the reporting scope yearly, establishing new data collection processes). Due to the varying and company-specific reporting scope we do not see any added value, as it prevents meaningful comparisons across years and between companies. We do not agree with the definition \"50 or more employees by head count and that are the 10 largest countries in terms of employee numbers for the undertaking\" for significant employment. The definition misleadingly implies a substantial employee presence in these countries, when in reality, the number of employees may be very small. In our case, these 10 countries also include countries that cover only 0.2 % of the total number of employees. The total number of employees should be shown by region, as the undertakings are easier to compare than by country breakdown. For this, a standardised definition of region should be used (e.g. UN classification). The regional breakdown enables to take a position on regional priorities, ","S1","S1-5 - Characteristics of the undertaking’s employees","23. (a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","In general, the reporting requirements are now more clearly defined. We welcome that the disclosure requirements have been narrowed down and that the word \"complaint\" has been removed. However, we suggest including as an application requirement that we can refer to G1 if our grievance mechanism also includes HR discrimination and/or human rights incidents.","S1","S1-16 - Incidents of discrimination and other human rights incidents","46."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","More clear to only refer to maternity leave. Open question: the basis to calculate the coverage is then only all female employees? Which would be different basis than calculating the coverage for the other life events.","S1","S1-10 - Social protection","34. (d)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","\nThe inherent diversity in national definitions for \"work-related accidents\" means that data collected from different countries within the same undertaking will not be directly comparable. This significantly complicates the ability to aggregate global health and safety data consistently, limiting an undertaking’s capacity to gain a holistic and accurate view of its performance across all operations, and provide precise and reliable information essential for robust management of health and safety aspects, as expected by financial markets.. Therefore, suggestion of deletion of “work-related accidents, the undertaking shall use the definitions as per the national laws of the countries where the employees are based.” Please add: \"However, the undertaking can use its own definition for accident. In this case it shall disclose that fact.\"","S1","S1-13 - Health and Safety metrics","AR 27"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Likewise, the use of estimates outside the workforce lacks conceptual coherence and may result in disclosures that are neither meaningful nor reliable.","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","AR 15"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We welcome the use of the average, because in case of averaging, consideration of additions and disposals pro rata, this reduces the calculation effort. This leads to better comparability for benchmarking by using a standardised average.\nHowever, we do not agree that the denominator \"by average number of employees\" includes 23 a (total number by number of employees). We would welcome it, if the involvement of employees by contract can be defined and described. If, for example, a large number of holiday workers are employed during the summer holidays, this drives up the fluctuation rate and distorts the informative value.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 13"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I agree","The elimination of the gender distinction in the training hours simplifies data collection and is therefore associated with less effort in the data collection process.","S1","S1-12 - Training and skills development metrics","38."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We agree that EFRAG also declined to give guidance about whether interns, trainees or inactive employees must be included as this depends on the national legislation. But to increases the transparency and comprehensibility of the data the undertakings must explain the sope \"total number of employe\" in a qualitative way and had to give feedback which employees are included or not. In our opinion, the explanation of this applied scope is particularly also necessary due to pragraph 23g \"in case of inconsistency between financial statement\".","S1","S1-5 - Characteristics of the undertaking’s employees","23 (g)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","ANNEX II to the [Draft] Amended ESRS Exposure Draft July 2025:\nThis definition, rooted in OSHA criteria, introduces ambiguity through two critical flaws: 1)Loss of Consciousness as a Standalone Criterion\nThe current framework treats all loss of consciousness incidents as recordable, regardless of causation (e.g., workplace hazards like chemical exposure vs. pre-existing conditions like epilepsy). This overinclusiveness distorts workplace safety metrics by conflating occupational and non-occupational factors. Further, severity variations (e.g. brief first-aid cases vs. multi-day absences) are unaddressed, preventing nuanced risk assessment.  2)Undefined \"Significant Injury\"\nThe term \"significant injury\" lacks objective parameters, leading to inconsistent interpretation across medical professionals and jurisdictions. For example, a laceration requiring stitches might be deemed \"significant\" in one context but not another. This subjectivity undermines data harmonization and comparative analysis. Suggestion to delete: Deletion of “loss of consciousness” and “significant injury”, remaining \"Work-related injury or ill health that results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid or ill health diagnosed by a physician or other licensed healthcare professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid\"","S1","S1-13 - Health and Safety metrics","40. (c)"]
["Excels","REWE Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Harmonize the calculation methodology with that applied in the context of the gender pay gap in order to promote methodological consistency and ensure comparability across reporting frameworks. Explicitly exclude board members (not only the highest paid individual) from the scope of remuneration metrics to ensure more meaningful and consistent disclosures.","S1","S1-15 - Remuneration metrics","44. (b)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","The term \"people\" should be added at the end of the following sentence :\"(employees working in a particular factory or geography or self-employed people)\".","S1","S1-1 - Policies related to Own workforce","11."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","The content \"with >50 employees\" in the table should be added in the following sentence: \"(for the EEA countries with >50 employees included in the ten largest countries)\". ","S1","S1-7 - Collective bargaining coverage and social dialogue","AR 17"]
["Excels","University of Warwick, Coventry, United Kingdom","Academia","United Kingdom",null,null,"I partially agree and partially disagree","Delete the final word “region” and insert “country”.  REASON: To disclose this information by region risks aggregating workforces in countries with widely divergent rates of securing collective bargaining agreements and so rendering the information misleading and uninformative. ","S1","S1-1 - Policies related to Own workforce","27. (c)"]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I partially agree and partially disagree","We strongly disagree with the removal of fatality disclosures for non-employees in ESRS S1-13. This change risks concealing serious safety incidents involving subcontractors and other third-party workers who often operate in high-risk environments. Fatalities among non-employees are not only tragic but also indicative of systemic issues in health and safety management. Their exclusion from mandatory reporting undermines the ESRS’s commitment to capturing material impacts across the full scope of the undertaking’s workforce.\n\nSubcontractors working on-site are frequently subject to the same operational risks as direct employees. Omitting their fatalities from disclosures creates a misleading picture of workplace safety and may reduce accountability for companies that rely heavily on outsourced labor. It also weakens alignment with international standards on occupational health and safety, which emphasize the importance of protecting all workers under an undertaking’s control.\n\nWe recommend reinstating the requirement to report fatalities among non-employees, particularly those working on-site or under direct supervision. Where full data is not available, a proportionality-based approach could be adopted to ensure meaningful reporting. Transparency in this area is essential to drive improvements in safety practices and uphold the ESRS’s social objectives.","S1","S1-13 - Health and Safety metrics","13."]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","ESRS S1 - AR 22 The simplification of the disclosure requirement is appreciated. However, the current wording does not sufficiently clarify how companies should proceed when national benchmarks differ significantly from EU adequate wage definitions. This is particularly relevant in countries like Germany, where the statutory minimum wage may not meet EU adequacy standards. We suggest adding a clarification that companies should disclose when national benchmarks are used and explain how they diverge from EU or ILO principles.","S1","S1-9 - Adequate wages","AR 22"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Using national definitions makes aggregation and comparability across countries nearly impossible, especially due to privacy laws (e.g., GDPR). This undermines ESRS objectives of transparency and consistency. Focus should be on “recordable work-related injuries” for feasible, comparable reporting.","S1","S1-13 - Health and Safety metrics","40.(c)"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","See our response to the questionnaire : Companies do not agree with the new definition of the treshold for reporting metrics disaggregated at Country Level","S1","S1-5 - Characteristics of the undertaking’s employees","AR 9"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I partially agree and partially disagree","To be relevant this disclosure should be based on the number of employees eligible for training and appraisal interviews, rather than the total number of employees. ","S1","S1-12 - Training and skills development metrics","AR 24"]
["Excels","GIFAS (Groupement des Industries Françaises Aéronautiques et Spatiales)","Business association (other than association of financial institution)","France",null,null,"I disagree","Interns and work-study students shall be excluded, and only the company's own workforce should be targeted.\nBenefits in kind will be very difficult to isolate and aggregate.","S1","S1-15 - Remuneration metrics","AR 36"]
["Excels","ETUC","Trade union","Belgium",null,null,"I partially agree and partially disagree","Datapoint on workers actually taking family-related leave should be reinstated","S1","S1-14 - Work-life balance metrics","42."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","\nFurther clarification needed for reporting on \"Days Lost\" : \n   - Clarify on whether it includes fatalities \n   - Clarify whether it includes only those occuring in the period, or those from a previous period but days lost in the current period, the cumulative amount of days included ?\n\n","S1","S1-13 - Health and Safety metrics","40. (e)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","We note that there are still redundancies and overlaps which could be further streamlined:  \n- 15a and 16 on insights and perspectives\n- 17 & 19a on remediation\n- 13 & 40a on management system related to H&S\n\nWe recommend that EFRAG review to see if these could be further streamlined. ","S1","S1 - Objective","1."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","it is required \"the number of fatalities from work-related injuries among everybody in the undertaking’s own workforce as well as other workers that work on its sites; […]\". Please clarify or delete \"among everybody\". It does not sound appropriate.","S1","S1-13 - Health and Safety metrics","40. (b)"]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","This metric is currently not reported by Equinor due to personnel privacy concerns. Given sensitivities suggest to at least set this as  ''may report'', not ''shall''.","S1","S1-13 - Health and Safety metrics","40. (e)"]
["Excels","UGT-ESPAÑA","Trade union","Spain",null,null,"I partially agree and partially disagree","Country-level information should be provided on the ratio of the higest paid individual in that country to the country median should be reported","S1","S1-15 - Remuneration metrics","44. (b)"]
["Excels","Danish National Funding Mechanism","(National) standard setter","Denmark",null,null,"I disagree","Please refer to our answer for Q27 in part 2. In addition to this we note that the requirement in ESRS-S1-27c refers to regions when being outside the EEA, which for annual reporting context makes more sense than individual countries. We believe this needs to be harmonised – referring to regions – or similar relevant aggregation for the reporting entity.","S1","S1-5 - Characteristics of the undertaking’s employees","23."]
["Excels","Danish National Funding Mechanism","(National) standard setter","Denmark",null,null,"I disagree","Regarding ESRS S1, paragraph 38b, we suggest that EFRAG carefully reconsiders the need for this, and if so, then how this can be measured in practice and become “decision useful”\nThe average number of training hours per employee is very difficult to calculate in practice for a modern workplace. We are concerned about whether this could be anything other than an estimate, as training in a modern workplace consist of 1) formal training, 2) informal training, 3) on the job training, 4) coaching & mentoring, 5) microlearning and 6) social & collaborative learning. Of which 5 out of 6 is not necessarily recorded, and the last (formal training), the hours are most often not recorded. Strong definitions as to expectations to what is included and how entities are expected to do complete reporting is needed in order to make the DR decision useful.","S1","S1-12 - Training and skills development metrics","38. (b)"]
["Excels","Anker Research Institute","NGO","United States",null,null,"I disagree","The basis of this calculation must indeed be the lowest wage but related to all individuals working in the company's operations, directly and indirectly employed, and so also including self-employed or sub-contracted workers (termed \"non-employees\" in the ESRS) working alongside directly employed workers but at risk of wage exploitation if not included in scope. Further, since human rights are universal, making a distinction between EU and non-EU countries as to how adequate wages are defined is not appropriate. ","S1","S1-9 - Adequate wages","AR 21"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","should a reference to sub-topic be included?","S1","S1 - Objective","5. (a)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Please note that for companies with legal entities operating across multiple countries, this may cause confusion. For example, it should be made clear whether the term \"workers' representative\" refers to representatives of the parent company or another specific entity. If the term is to be understood in a broad sense, collecting and disclosing the relevant information could prove challenging.","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","15."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","we would suggest to add here \"whether at the end of the year, in average or both\"","S1","S1-5 - Characteristics of the undertaking’s employees","23."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","there is not a particular requirement requesting for number of employees by gender. \n\nAs stated in paragraph 49, it appears that the number of employees should be reported with a breakdown by both country and gender simultaneously, rather than separately in two different tables.\n\nAdditionally, in:\n50 a) number of employees by gender and countries\n50 b) total number of employees\n50 c) permanent breakdown by gender\n50 d) temporary breakdown by gender\n\n\n\ni would suggest to remove this table or provide related clarifications","S1","S1-5 - Characteristics of the undertaking’s employees","AR 11"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","pls bear in mind that depending of the country, the statutory minimum wage may be set in by year, month or even day. This could add complexity to this requirement, particularly for companies which operate in multiple countries aroun the globe.","S1","S1-9 - Adequate wages","AR 22"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We would suggest to align this disclosure requirement with GRI 401-3, to ensure consistency. \nIn this regard, GRI is asking by parental leave (parental leave - leave granted to men and women employees on the grounds of the birth of a child).","S1","S1-14 - Work-life balance metrics","42."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","please clarify whether figures should be reported:\n- In head count, full-time equivalent (FTE), or both?\n- At the end of the reporting period, as an average across the reporting period, or both?","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","25."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","We do not support the new threshold proposed for reporting metrics disaggregated at country level in draft ESRS S1-5 and S1-7 (S1 -23(a), S1- 27(b) and S1–28(a)). The new threshold (10 largest countries in terms of employee numbers) contradicts/dilutes the principle of only reporting material information. We recommend maintaining the current threshold of 10% of total number of employees. The updated/new definition in draft ESRS S1-5 and S1-7 would expand the data gathering efforts for the disclosure, with minimal value added because the new threshold would entail that countries with a relative low percentage of total workforce would need to be disclosed despite their relatively little effect on the undertaking.","S1","S1-7 - Collective bargaining coverage and social dialogue","28. (a)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I agree","According to German law and applicable bargaining agreements, there are multiple forms of carer's leave (Sonderurlaub für Pflege) which can be taken also for serious medical reasons but encompass all medical reasons that are not classified as serious. The reason for taking the carers' leave cannot be specified to the extent that the undertaking cannot verify whether a serious medical reason was existent or not considering the applicable data protection regulations. Please specify whether the carers' leave encompasses leaves which can include leave to provide personal care in general without the possibility of verification of extent of the required degree of medical seriousness or care.","S1","S1-14 - Work-life balance metrics","AR 32"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nRedundant to GDR-A\nSuggestion:\nDelete","S1","S1-3 - Actions and Resources related to Own workforce","AR 6"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,null,"Proper instructions for the gender category “other” are missing. For reasons of respect and inclusion, it should be addressed with clear reporting guidance on how to handle it. The current S1-15 is very negative in this regard.","S1","S1-15 - Remuneration metrics",""]
["Excels","IMA-Europe ","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","There is an inconsistency with the disclosure requirement. Work-related accidents is a new term that is defined in the glossary as including ill-health and fatalaties. The disclosure requirements makes reference to all three things (work-related accidents, ill-health and fatalities). The latter two should be deleted from the sentence.","S1","S1-13 - Health and Safety metrics","13."]
["Excels","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Adjusted gender pay gap should remain a voluntary option as this figure is much more meaningful","S1","S1-15 - Remuneration metrics","44. (a)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","With respect to non-guaranteed hours employees breakdown by gender should be added - this would also be in line with AR 12. The total head cout of employees should also be provided as other metrics (e.g. non-employees, health & safety management system coverage) are also provided in head counts and they require contextual information of total head count. The numbering should be amended.","S1","S1-5 - Characteristics of the undertaking’s employees","23. (b)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","S1-6 should also be material if own-workforce topic is material.","S1","S1 - Objective","3."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","In order to ensure consistency, it should be indicated that the undertaking should use the same manner of presentation (head count vs. FTE) as in S1-5 par 23(b).","S1","S1-12 - Training and skills development metrics","AR 24"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Maybe add; depending on defenition from national legislation (analogue to #8)","S1","S1-5 - Characteristics of the undertaking’s employees","23. (b)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Consitency on the use of head count versus FTE\nWe recommend that the use of the terms ‘employees’, ‘non-employees’ and ‘own workforce’ is more prominent in the DRs to make it clear on the scope for each DR. This could be explicitly included in the DR name for example.                        \n        ","S1","S1-5 - Characteristics of the undertaking’s employees","AR 11"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Does the undertaking exclude all employees in countries/regions where there is a legal restriction to collecting data? Or is this then assumed to be zero percent in those countries/regions?","S1","S1-11 - Persons with disabilities","36."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,null,"DASB asks for clarification. Is it unclear whether especially under b iv) may differ from accounting requirements; maybe exemption that you can simply use the figures as applied for financial reporting purposes?","S1","","AR 36"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","For this data point no information can be gathered due to lacking access to data.  Data points for which no information can be gathered due to lacking access to data should be deleted from the ESRS Set 1.","S1","S1-7 - Collective bargaining coverage and social dialogue",""]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Employees with another Gender than male or female will not be represented in this metric. ","S1","S1-15 - Remuneration metrics","44. (a)"]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I disagree","This change brings no relevance to the table and renders the concept of significative country less practical, it may inflict an undue charge of work on smaller entities for bigger groups, hence going against the concept of simplification. We suggest reverting back to 10% total employees + 50+ employees.","S1","S1-5 - Characteristics of the undertaking’s employees","23. (a)"]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","Precision on the methodology while useful for comparability, here means all historic values won't be comparable t o the new one when changing methodology, making reports unequal between companies that already had that methodology and others.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 13"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","(a) We suggest to append 2nd line  where examples are given for channels with phrase \"for example but not limited to..\" to ensure that it is open and not interpreted as only those in example.\n(b) Last sentence need to be clarified - \"..as well as, under certain circumstances whistleblowing mechanisms.\". What are those circumstances, why do not we simly include that mechanism?","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","AR 3"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","\"Disregarding differences in national legal definitions\" will provide an inaccurate total number. Suggest removing requirement to count temporary or non-guaranteed hours employees.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 9"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","\"significant\" term is not clear how to be applied (2nd line)","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","AR 14"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Please refer to question 31 of the General section ","S1","S1-15 - Remuneration metrics","44. (a)"]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We support the changes proposed.","S1","S1-4 - Targets related to Own Workforce","4."]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Social protection against listed major life events is publicly driven, and does not depend on the organization. There is a risk of lengthy disclosures and more excessive than in previous format. Could be limited to a principle of the 10 largest countries or another threshold. ","S1","S1-7 - Collective bargaining coverage and social dialogue","10."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The publication of remuneration ratios is problematic because it can reveal sensitive information about individuals (data protection). In addition, the ratio is often distorted and not very meaningful, especially in small or specialised companies. Finally, there is a lack of clear methodological standards for calculation (gross/net, bonuses, full-time equivalents, etc.), which further limits comparability and meaningfulness -> deletion","S1","S1-15 - Remuneration metrics","44. (b)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","15."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","AR 2"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","new disclosure requirement description without helpful examples","S1","S1-3 - Actions and Resources related to Own workforce","AR 6"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit","S1","S1-5 - Characteristics of the undertaking’s employees","23. (b)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit","S1","S1-5 - Characteristics of the undertaking’s employees","AR 9"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","Unchanged","S1","S1-7 - Collective bargaining coverage and social dialogue","27. (a)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit - Editorial change","S1","S1-7 - Collective bargaining coverage and social dialogue","28. (b)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit - Merged and consolidate former 69 and 70","S1","S1-9 - Adequate wages","32."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","Unchanged","S1","S1-10 - Social protection","34. (c)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","Inclusion of new formula","S1","S1-12 - Training and skills development metrics","AR 24"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","simplification edit - deletion of the datapoints related to ill-health for non-employees and workers in the value chain. Reduction of scope of the metric","S1","S1-13 - Health and Safety metrics","40. (b)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit - Editorial change","S1","S1-13 - Health and Safety metrics","AR 30"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit - Editorial change","S1","S1-15 - Remuneration metrics","43."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit - Editorial change","S1","S1-16 - Incidents of discrimination and other human rights incidents","45."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","simplification edit - Editorial change","S1","S1-16 - Incidents of discrimination and other human rights incidents","AR 39"]
["Excels","Statkraft AS","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I agree","Agree with the changes whereby no ESRS 2 specifications for SBM in the topical standards. Reduce repetition.  ","S1","S1 - Interaction with other ESRS","10."]
["Excels","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland",null,null,"I partially agree and partially disagree","Age distribution should not be deleted, as it provides crucial information on the characteristics of workforce, which is relevant for a whole host of IROs, e.g. aging of the workforce","S1","S1-8 - Diversity metrics","29."]
["Excels","Central Organisation of Finnish Trade Unions SAK","Trade union","Finland",null,null,"I partially agree and partially disagree","Country-level information should be provided on the ratio of the higest paid individual in that country to the country median should be reported","S1","S1-15 - Remuneration metrics","44. (b)"]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I disagree","This data is very difficult to aggregate at group level. Definitions vary from one country to another. The company cannot collect individual data. The data is aggregated at country level, so it cannot be verified, which will complicate the audit.","S1","S1-11 - Persons with disabilities","AR 23"]
["Excels","MEDEF","Business association (other than association of financial institution)","France",null,null,"I disagree","The same remuneration elements should be provided for both indicators – why is only the ratio (AR36) detailed and not AR 35? The requirements for collecting data on the pay ratio are too burdensome, and we would be in favor of aligning its calculation basis with that of the gender pay gap, which is simpler and more realistic for large global groups.","S1","S1-15 - Remuneration metrics","AR 35"]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The expectation to avoid duplication entirely is unrealistic and potentially counterproductive. In practice, overlapping or identical reporting content is required across multiple disclosure requirements, which creates confusion for undertakings. Faced with ambiguity, companies are likely to over-comply to avoid the risk of non-compliance or penalties—undermining the goal of streamlined and efficient reporting.","S1","S1 - Objective","5. (b)"]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The requirement to disclose communication channels for policies is redundant, overly granular, and goes beyond the CSRD. This disclosure was intentionally removed from ESRS 2 and should not be reintroduced in topical standards. If guidelines for policy disclosure are not streamlined in ESRS 2, this will lead to inconsistent presentations across standards and increased reporting burden. To ensure clarity, comparability, and proportionality, AR 1 should be deleted.","S1","S1-1 - Policies related to Own workforce","AR 1"]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The definition of “channels” is overly broad and lacks clarity, risking inconsistent interpretation and reporting across undertakings and Member States. The inclusion of third-party and external mechanisms (such as NGOs or industry associations) goes beyond the CSRD’s intent and established national practices. This could create legal uncertainty and unnecessary reporting burden, especially where such channels are not under the undertaking’s control.  Whistleblowing channels are typically regulated by specific national or EU legislation (e.g., the EU Whistleblower Directive) and are designed for reporting legal violations, not general workforce concerns. Mandating their disclosure in this context risks conflating distinct legal frameworks and could undermine the protective intent of whistleblowing laws. The standard should focus on channels directly established or managed by the undertaking and clarify that only material, relevant channels must be disclosed. Overly prescriptive or open-ended requirements should be avoided to ensure proportionality and comparability.","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","AR 3"]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","While the CSRD mandates a dialogue with workers’ representatives, this paragraph’s requirement to disclose engagement specifically on \"target-setting\" is an overreach.\nWorker consultation and co-determination are highly regulated and sensitive areas governed by diverse national laws and established practices across the EU. By imposing a uniform, granular disclosure requirement on the process of setting strategic targets, the ESRS interferes with these carefully balanced national systems. It creates a de facto European standard that runs parallel to, and potentially conflicts with, existing national legal frameworks, infringing upon both corporate governance structures and the specific rights and duties established in member states.\nThis represents a clear intrusion into entrepreneurial freedom and national legal competences. The reporting standard should not be used to harmonize complex national labor relations through the back door.\nTherefore, this paragraph must be deleted. The general obligation for dialogue is set by the CSRD, and its practical application is properly managed by the applicable national laws on co-determination.","S1","S1-4 - Targets related to Own Workforce","21."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This Application Requirement is overly simplistic and prescribes a one-size-fits-all calculation that fails to reflect diverse business realities.\nThe mandated formula for employee turnover aggregates vastly different reasons for departure—voluntary leave, dismissal, retirement, and death—into a single, crude metric. This approach is methodologically weak, as it obscures the underlying drivers of turnover. For example, a high turnover rate due to retirements in an aging workforce has a completely different strategic implication than one caused by dismissals or voluntary departures.\nBy forcing a single, non-nuanced calculation, the standard produces a metric that is of limited value and can be highly misleading. It infringes upon a company's ability to report on workforce dynamics in a way that is meaningful and relevant to its specific situation, industry, and strategic context.\nTo provide decision-useful information, this AR should be amended to allow companies to use their own established and more contextually relevant methodologies for calculating and explaining employee turnover, rather than mandating a single, overly simplified formula.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 13"]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This paragraph's objective is overly narrow and reductionist. It incorrectly equates the broad concept of \"diversity\" with a single, prescribed metric: \"gender diversity at top management level\".\nThis one-size-fits-all approach is flawed as it disrespects the undertaking's own materiality assessment and fails to reflect the broader scope of diversity outlined in the CSRD itself. The directive lists multiple grounds for equal treatment, including age, disability, and racial or ethnic origin, not just gender. The aspects of diversity that are most material will vary significantly between companies.\nTherefore, this narrow objective should be deleted. It should be replaced with a principles-based objective that enables an understanding of the company's overall approach to diversity and inclusion, allowing undertakings to report on the specific topics and metrics they have identified as material for their business. This ensures the information is relevant and aligns with the holistic view of diversity intended by the CSRD.","S1","S1-8 - Diversity metrics","29."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This paragraph's requirement for a binary \"yes/no\" disclosure on paying an \"adequate wage\" is unworkable and fundamentally flawed.\nThe term \"adequate wage\" lacks a single, legally binding, or universally accepted benchmark, especially across different countries. It is a complex socio-economic concept, not a simple compliance check. Forcing a company to make a definitive \"yes/no\" statement against such a vague and subjective standard is misleading and creates significant legal uncertainty.\nDifferent companies will inevitably use different benchmarks, making any disclosures non-comparable and of little value to stakeholders. This requirement forces companies into a disproportionate and legally precarious exercise of judging their own wage practices against a non-existent standard.\nGiven the lack of a clear and objective benchmark, this disclosure requirement is not fit for purpose and should be deleted.","S1","S1-9 - Adequate wages","32."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This paragraph is unworkable, legally precarious, and imposes a disproportionate burden.\nIt requires an undertaking to make a definitive assessment of whether its employees \"lack social protection\". This is practically impossible, as a company cannot reliably possess or verify the detailed, personal information needed to determine the social security coverage of every individual employee. Requesting such sensitive data would likely violate data protection laws.\nFurthermore, companies already adhere to all applicable national social policy laws. Reporting on the outcomes of these legally mandated systems - in terms of the elements mentioned in a)-d) -  is redundant and provides little value to users.\nGiven that the disclosure is unfeasible, legally problematic, burdensome, and redundant, this paragraph must be deleted.","S1","S1-10 - Social protection","34."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This objective is redundant and leads to a disproportionately burdensome reporting exercise that is not fit for purpose.\nOccupational health and safety is already governed by strict and comprehensive national laws and regulations in Member States, which are monitored by state authorities and accident insurance bodies. Companies are already legally required to comply with these high standards. Demanding a separate, standardized report on this topic is a redundant exercise in documenting existing legal compliance and provides no added value.\nThe definitions of \"work-related accidents\" and \"ill-health,\" as well as the specific legal requirements, differ significantly across countries. This makes it impossible to produce a single, standardized set of metrics that would be meaningful or comparable across the EU.\nGiven that this area is already heavily regulated at the national level and a standardized, comparable report is practically impossible, this Disclosure Requirement is superfluous. It should be deleted.","S1","S1-13 - Health and Safety metrics","39."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This paragraph is redundant and legally problematic.\nEntitlement to family-related leave is comprehensively regulated by binding national law in all Member States. Companies are already legally required to grant these entitlements. Disclosing a percentage of entitled employees is a superfluous exercise in documenting existing legal compliance and provides no meaningful insight into a company's performance.\nFurthermore, determining an individual employee's specific entitlement often depends on personal circumstances (e.g., the age of a child, the health of a relative). Requesting such sensitive personal information from the entire workforce to calculate a percentage raises significant data privacy concerns and is a disproportionate intrusion.\nGiven that this requirement is redundant and legally problematic, it should be deleted.","S1","S1-14 - Work-life balance metrics","42."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The term “incident” is not clearly defined, creating legal uncertainty for companies. It is unclear whether all allegations, including unsubstantiated or minor complaints, must be reported, or only substantiated and material cases. This ambiguity risks inconsistent reporting and undermines comparability.\nCollecting and disclosing data on discrimination or human rights incidents may conflict with national data protection laws (e.g., GDPR). In many jurisdictions, companies are prohibited from processing or publishing sensitive personal data, especially if individuals could be identified.\nCompanies are already subject to strict anti-discrimination laws and national frameworks (e.g., AGG in Germany). Additional reporting obligations create unnecessary administrative burden without added value, as legal remedies and sanctions already exist.\nThe DR does not distinguish between material and immaterial incidents. Reporting all incidents, regardless of severity or outcome, may lead to information overload and reputational harm based on unsubstantiated claims, rather than focusing on genuinely material risks.\nDisclosure should be limited to substantiated, significant cases, in line with national legal definitions and only where reporting is legally permissible. Clear definitions and thresholds are needed to ensure legal certainty, proportionality, and relevance.","S1","S1-16 - Incidents of discrimination and other human rights incidents","45."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The instruction to cross-reference how incidents have been addressed with DR ESRS S1-3 is redundant and adds unnecessary complexity. DR S1-3 already requires disclosure of actions and resources related to managing material impacts, including remediation processes. Repeating this requirement here does not provide additional value and may lead to duplicative or fragmented reporting.\nTo avoid unnecessary duplication and ensure clarity, the standard should require reporting on remediation actions only once, with a clear reference to the relevant section. Cross-references should be minimized to streamline reporting and reduce administrative burden.","S1","S1-16 - Incidents of discrimination and other human rights incidents","AR 40"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","The first part of the paragraph is coved by GDR-A ? Why do we need to reapeat it?  ","S1","S1-3 - Actions and Resources related to Own workforce","19. (a)"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I disagree","Need to be clarified.","S1","S1-3 - Actions and Resources related to Own workforce","AR 6"]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","We propose re-integrating the total number of employees who have left the undertaking, since it remains essential for calculating the turnover rate and its exclusion therefore results in only an apparent simplification.","S1","S1-5 - Characteristics of the undertaking’s employees","23. (c)"]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We propose re-integrating from NMIG for ESRS S1-15 the \"NMIG 35 for para. 44 \" in the main standard as a mandatory Data Point to ESRS S1 para 44. We propose retaining in the main standard as a new Application Requirement to ESRS S1 para 44.\n\nFurthermore, we propose restoring former paragraphs 98 and 99, as they add useful detail to gender pay gap reporting. In particular, we suggest para 98, which requires disclosure of the gender pay gap by employee category (and, where applicable, by country), to be a “shall” requirement; while para 99, which introduces the adjusted gender pay gap to account for differences in purchasing power, as to be disclosed where relevant.","S1","S1-15 - Remuneration metrics","44."]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","We welcome the fact that companies can use their own definitions, but only in addition. The first step must be mandatory reporting according to the definition of \"top management\".  If the own definition will be used, we agree with the obligation to disclose. ","S1","S1-8 - Diversity metrics","AR 19"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","The legal text now specifies exactly how the distribution must be reported; distribution in number (head count) and percentage.","S1","S1-8 - Diversity metrics","30."]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We disagree with the delete of the definition \"non-guaranteed hours employees\" and we strongly recommend to keep this definition. This definition has supported us in establishing a reporting approach and has now been recognised and accepted in the whole undertaking  worldwide. Without this definition, we have difficulties with the worldwide data collection, the KPI has no meaningfulness and cross-company comparability is not guaranteed in the future.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 9"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","In order to data quality and comparability, the definition of \"non-guaranteed\" rather should be concretised clearly and not consistently removed. It is clear that this category includes \"own workforce\" employees, not \"non-employees\" or \"value chain workers,\" and these employees do not have guaranteed minimum working hours. However, it is not explicitly stated if \"non-guaranteed hours employees\" only include on-call workers considered vulnerable workers. It should be clarified whether non-guaranteed hours employees only include on-call workers or also include employees without guaranteed hours but with mutual agreements on work availability.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 9"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","We agree that total number of non-employee only have to be reported, when they are significant driver of IROs. But it is not clear when this situation arises. The definition \"key part of the undertaking's business model, for example when they are used to provide flexible labour or when they are used in key processes\" is missing. Possible interpretation: If we would not use the non-employees model, the business could not be continued. We recommend to clarify the definition accordingly.","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","AR 14"]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","We do not support the removal of the “severity” concept from ESRS S1-16 § 46b). The previous focus on severe human rights incidents provided a clear and operational threshold for reporting, which enabled consistent and justifiable disclosures—such as the exclusion of non-severe cases from our 2024 reporting.\nEliminating this threshold introduces ambiguity and would require us to define our own criteria for inclusion, particularly in areas like occupational safety or freedom of association. This increases complexity and audit effort while undermining comparability. For example, we are not classifying occupational safety issues as human rights violations under the LkSG framework, given our robust governance and preventive measures.\nWe believe that fair and decision-useful reporting requires clear boundaries, and the removal of the severity filter undermines this principle.","S1","S1-16 - Incidents of discrimination and other human rights incidents","46. (b)"]
["Excels","PwC International Limited","Auditor","United Kingdom",null,null,"I agree","There are currently two different definitions of work-related accidents—one definition in ESRS S1 AR 27 and a separate definition in Annex II. We recommend the definition in ESRS S1 AR 27 is retained. In addition, the phrase ‘work-related accidents’ should be removed from ESRS S1 paragraph 40(e) because it is duplicative with the work-related injuries and work-related ill-health already included in ESRS S1 paragraph 40(e). ","S1","S1-1 - Policies related to Own workforce","40."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","We would like EFRAG to clarify how the tensions between actions and other business pressures should be disclosed.","S1","S1-3 - Actions and Resources related to Own workforce","19. (a)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","The changes have enhanced clarity.","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","24."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I agree","The changes have enhanced clarity.","S1","S1-6 - Characteristics of non-employees in the undertaking’s own workforce","25."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","We suggest to align this DR with the new DR S1-6, meaning the disclosure of data regarding non-employees should be required only if such categories are material.","S1","S1-13 - Health and Safety metrics","40."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The concept of incidents and how to identify them is still unclear. Among Disclosure Requirements, Application Requirements and the Glossary there are several definitions of incidents and confirmed/substantiated incidents. We suggest the best approach would be having specific definitions for each case (e.g. human rights incidents, incidents of corruption and bribery, etc.) and presenting them under the related application requirements. Such definitions would then include detailed explanations of:\na) the scope of the matter (e.g. “discrimination at work on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination, including harassment”); and\nb) the type of instances that trigger the reporting of the corresponding metrics (e.g. “judicial and non-judicial proceedings that have been initiated such as cases before domestic courts, mediation, complaints filed with the National Contact Points for OECD Multinational Enterprises”).\nIn our view the best path to support simplification in relation to point (b) above would be to focus on incidents that have been confirmed through a final decision issued by a court of law or relevant authorities.","S1","S1-16 - Incidents of discrimination and other human rights incidents","46. (a)"]
["Excels","Japan Business Council in Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Comment:\nWhen applying the ESRS at the consolidated level—particularly when the ultimate parent company is located outside the EU—collecting gender-related data presents challenges. In certain jurisdictions, legal or cultural norms discourage or prohibit the collection or disclosure of gender identity information.\n\nRecommendation:\nAllow undertakings the flexibility to report the number of employees either by sex or by gender, depending on what is legally permissible in each jurisdiction.","S1","S1-5 - Characteristics of the undertaking’s employees","5. (a)"]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","ANNEX II to the [Draft] Amended ESRS Exposure Draft July 2025:\nThis definition, rooted in OSHA criteria, introduces ambiguity through two critical flaws: 1)Loss of Consciousness as a Standalone Criterion\nThe current framework treats all loss of consciousness incidents as recordable, regardless of causation (e.g., workplace hazards like chemical exposure vs. pre-existing conditions like epilepsy). This overinclusiveness distorts workplace safety metrics by conflating occupational and non-occupational factors. Further, severity variations (e.g. brief first-aid cases vs. multi-day absences) are unaddressed, preventing nuanced risk assessment.  2)Undefined \"Significant Injury\"\nThe term \"significant injury\" lacks objective parameters, leading to inconsistent interpretation across medical professionals and jurisdictions. For example, a laceration requiring stitches might be deemed \"significant\" in one context but not another. This subjectivity undermines data harmonization and comparative analysis. Suggestion to delete: Deletion of “loss of consciousness” and “significant injury”, remaining \"Work-related injury or ill health that results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid or ill health diagnosed by a physician or other licensed healthcare professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid\"","S1","S1-13 - Health and Safety metrics","40. (c)"]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The added mandatory requirements (reference to materials impacts, risk and opportunities) could potentially increase the reporting complexity","S1","S1-1 - Policies related to Own workforce","12."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I agree","The amendments to the requirements on how a company engages with its own workforce streamlined the process","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","15."]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Agree","S1","S1-13 - Health and Safety metrics","14."]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Paragraph 89: agree with the deletion ","S1","S1-13 - Health and Safety metrics","13."]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I agree","AR 87: agree with the deletion ","S1","S1-13 - Health and Safety metrics","13."]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","AR in general: Suggestion: Use and link to GRI 403 Standards to ensure that basic requirements are met.","S1","S1-13 - Health and Safety metrics","13."]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I agree","The term ‘diversity’ does not correspond to the indicator, which only measures gender distribution","S1","S1-8 - Diversity metrics","AR 19"]
["Excels","Afep","Business association (other than association of financial institution)","France",null,null,"I disagree","Our requests for amendments have not been taken into account; the definition of incident of discrimination is still too broad. It shall be limited to proven and dealt with incidents, i.e. those that have resulted in a final court decision.","S1","S1-16 - Incidents of discrimination and other human rights incidents","AR 37"]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I disagree","(Part 2): We believe that “Non-employees” can never be regarded as part of an entity's own workforce from a financial or strategic perspective. From an operational and workforce planning perspective, it makes sense to include the non-employees. The premise for reporting is a clear distinction between the two and ensure consistency in the Annuel Report i.e. financial FTE is based on \"people” who are in an employment relationship with the undertaking only and does not include non-employees. \n\nWe believe the only solution is to delete ESRS S1, paragraph 25, (disclose the number of non-employees) and instead put more emphasis on the narratives as we suggest in the comments to ESRS S1, paragraph 24.\n\nThis also makes sense as to consistency to the other elements in S1, where employee statistics are only required for employees.","S1","S1 - Objective","7."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I disagree","We suggest deleting ESRS-S1-21\nWe believe the content of this DR is already covered by ESRS-S1-20 as well as the other requirements around stakeholder engagement.\nThe content in 21 could be part of the NMBIGNBMIGNMIGNMIGNMIG-document, but we suggest deleting this as an DR as it from our perspective only add complexity.","S1","S1-4 - Targets related to Own Workforce","21."]
["Excels","Danish Industri","Business association (other than association of financial institution)","Denmark",null,null,"I partially agree and partially disagree","Partially disagree \nWe do not agree with the first sentence in the AR “The undertaking shall present the requested disclosures either in a narrative format or following the table below …”\n\nWe agree that the information can be provided both in a narrative way as well as in a tabular format, but we do not agree with mandating the specific tabular format no limiting the use of other presentation formats, like graphs. We believe the tabular format should be only an example, located in the NMIG.","S1","S1-7 - Collective bargaining coverage and social dialogue","AR 17"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","The requirement is not clear - what does not apply if a sub-topic is material? How do the two requirements work together (if the topic is material and specific sub-topics also material)? NB also the note on p10 NMIG on own workforce/human rights which is not understandable but is important guidance that clearly relates to S1:3.","S1","S1 - Objective","3."]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","As drafted this paragraph requires the use of a highly significant judgement for both the entity and the auditor as to determine whether there is a lack of social protection. In addition restricting disclosures to instances of lack of social protection is in practice a 'net' approach in assessing the materiality  of information which is not consistent with the overall approach set out in ESRS 1. Should EFRAG not change this proposal, it is necessary to provide an auditable framework that defines social protection - and the lack of -  for example by reference to an international framework such as ILO. We suggest retaining the reference to 'parental leave,' or replacing it with 'family-related leave', as defined in the glossary to include paternity leave, parental leave, and carers’ leave.","S1","S1-10 - Social protection","34."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","NMIG 3 for para. 11\nCommunication channels were removed from MDR-Ps, why bringing them up here introducing additional requirements (even as \"possible elements\")? If the guidelines on how to disclose information on policies are not streamlined in ESRS 2, this will lead to different way of presentation across the standards. Possible solution: streamline in ESRS 2 or eliminate completely.","S1","S1-1 - Policies related to Own workforce","11."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","ESRS S1.19a is a duplication of ESRS S1.18. This may simply be a clarification regarding \"key actions\" in relation to \"material negative impacts\".","S1","S1-3 - Actions and Resources related to Own workforce","19. (a)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","RED FLAG\nThis disclosure requirement distinguishes between work-related a) injuries, b) accidents, c) ill health and d) fatalities. However, much of the information requested is difficult or impossible to collect. Work-related ill health could, for example, only become apparent decades after the end of employment, or the proportion of work contributing to the illness is uncertain, which is why the reporting undertaking has no knowledge of such circumstances. Furthermore, due to data protection regulations, reporting entities do not know whether an employee is absent due to a) injury or b) ill health.Therefore, only information on a) injuries, b) accidents, c) ill health and d) fatalities that are ‘subject to other legal recording and reporting requirements’ should be reported.","S1","S1-13 - Health and Safety metrics","40."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","We would like to point out that the newly introduced definition of “non-employees” based on national legislation (par.8 and AR 9) will result in additional complexity for multinational undertakings, who may have adopted a different approach (e.g., Group-level definition) in their reporting. We suggest aligning all S1 provisions with the approach of AR 23 for para. 36 (disability), that allows flexibility to undertakings on the definition to adopt (national legislation or Group-level.","S1","S1-1 - Policies related to Own workforce","8"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I disagree","Change in definition/threshold of significant headcount for the metrics regarding characteristics of the undertaking’s employees, collective bargaining coverage and social dialogue in the European Economic Area (S1-5 and S1-7 of Amended ESRS S1) leads to additional effort as it triggers changes in methodology and additional disclosure requirements. In particular, with respect to S1-5 and S1-7 this additional effort to collect the relevant data is considerable.","S1","S1-5 - Characteristics of the undertaking’s employees","23(a)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","The amended wording replaces “number of severe human rights [incidents/issues]” with “number of human rights [incidents/issues].” This broadens the scope from substantiated, high-impact cases to potentially all recorded incidents, regardless of severity. It also risks undermining alignment with SFDR PAI Indicator #14, which refers to “identified cases of severe human rights issues and incidents”. We recommend reintroducing the qualifier “severe” to ensure conceptual clarity and consistency.","S1","S1-16 - Incidents of discrimination and other human rights incidents","46(b)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","The paragraph does not require to report key actions taken, planned or underway to cause positive impacts and to manage risks and opportunities. It should also require these actions because this would be critical for undertakings that did not identify material negative impacts.","S1","S1-3 - Actions and Resources related to Own workforce","19(a)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","The newly introduced definition of “work-related accidents” based on national legislation (par.8 and AR 9) will result in additional complexity for multinational undertakings, who may have adopted a different approach (e.g., Group-level definition) in their reporting. We suggest aligning all S1 provisions with the approach of AR 23 for para. 36 (disability), that allows flexibility to undertakings on the definition to adopt (national legislation or Group-level).","S1","S1-13 - Health and Safety metrics","AR 27 for 40 (c)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Either move this to ESRS 2 GDR-P, as it is a general disclosure no matter if the sub-topic \"Health&Safety\" is material, or delete it and only state a health & safety policy if health&safety is material for this company. This again does not follow the overall systematic.","S1","S1-1 - Policies related to Own workforce","13."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I agree","Reduction is perceived very well.","S1","S1-5 - Characteristics of the undertaking’s employees","38. (a)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","It is recommended that these metrics should be voluntary and only necessary if the sub-topics of discrimination and human rights incidents are material. The scope of mandatory metrics need to be clarified so that there is no variation in interpretation between undertakings.","S1","S1-16 - Incidents of discrimination and other human rights incidents","46. (a)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Correction: MDR-T --> GDR-T","S1","S1-11 - Persons with disabilities","23."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The life areas of social security are not clear after discussion with several experts worldwide: Most of the time, the topic acquired disability is secured via the health insurance. So the five areas are not separate, rather then intertwined, at least for reason 1 and 3.","S1","S1-10 - Social protection","34. (a)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","Inclusion a reference that persons of disabilities definition may be different per country regulation","S1","S1-11 - Persons with disabilities",""]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Conflicting definitions and guidance regarding \"incident\":\nDefinition of incident in glossary does not refer to \"substantiated\". The metric for incidents of discrimination requires incidents to be counted and these should be substantiated incidents.\nAR38 refers to substantiated incidents. The definition of what needs to be counted should be in one place.\nOr, similar to the new definition of \"confirmed human rights incidents\", please introduce a definition of \"confirmed disrimination incidents\" which is what the metric should be measuring.\nUse of the word \"incident\" and its definition needs to be cleaned up as currently extremely burdensome to follow what is required.","S1","S1-16 - Incidents of discrimination and other human rights incidents","AR 38"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","Deletion of requirement to show non guaranteed hours headcount by gender is welcomed. But not clear on rationale for why this has been deleted but not other detailed breakdowns. How are EFRAG decisions made regarding usefulness of information - how are non guaranteed hours deemed not significant enough to do by gender but other categories are?","S1","S1-5 - Characteristics of the undertaking’s employees","23. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","In the absence of a clear definition (definition in glossary is extremely vague), the deleted guidance was helpful to use as a definition for what was being reported and made the disclosure more meaningful. Suggest to provide clearer definition (use previous AR75).","S1","S1-10 - Social protection","34."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","AR83-88, 92: Deletion of useful guidance in the absence of clear definitions which are subject to judgement. Suggest moving to NMIG.","S1","S1-13 - Health and Safety metrics","40."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","We have noticed that there has been a change in the calculation (the denominator). Currently the selection of the denominator  is open to companies, but the revision stipulates \"average employee headcount\" this will result in comparative figures not being comparable after revision. Suggest to revert back to original requirement.","S1","S1-5 - Characteristics of the undertaking’s employees","AR 13"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Just transition: If this section is retained, add the interaction with environmental topics (“just transition”) as an interaction with other standards","S1","S1 - Interaction with other ESRS","10."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Contextual information: Delete AR on contextual information, as it duplicates the content of ESRS 2 GDR-M\nHeadcount methodology: Clarify in AR that that the annual average of monthly headcount during the reporting period is more appropriate than the year-end headcount, as it better represents the workforce over time; and mention in AR that FTE may be more suited for seasonal activities","S1","S1-5 - Characteristics of the undertaking’s employees","AR 10"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Gender pay gap: replace by a breakdown of gender pay gap by employee category and at country or geographical levels, as it is the main driver of the pay gap, consequently both preparers and users stress that it is necessary to ensure the relevance of the metric disclosed.","S1","S1-15 - Remuneration metrics","44. (a)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","AR 22 for paragraph 32 shares new methodology to determine ESRS S1-9 §32 datapoint. In addition to our comments in Part 2, we suggest EFRAG to provide some tools to assist preparers in assessing adequacy of wages. \n\nFor non-EU countries, we recommend EFRAG clarifies:\n- where the undertaking shall find the list of countries where wage has been set according to ILO wage setting principles (e.g. provide confirmation if the list in the following link corresponds to the list of countries having ratified C131 - Minimum Wage Fixing Convention, 1970  : https://normlex.ilo.org/dyn/nrmlx_en/f?p=NORMLEXPUB:11300:0::NO::P11300_INSTRUMENT_ID:312276)\n- where the undertaking shall find the list of institutions, mandated by the public authorities of the country where the workers are based, having estimated local wage according to  ILO wage setting principles\n- where the undertaking can find a tool allowing to assess local wage according to  ILO wage setting principles.\n\nFor EU countries, we recommend EFRAG checks that adequate minimum wages will be available in all EU Member states at the date of the first application of the new set of ESRS, which implies that the Directive (EU) 2022/2041 of the European Parliament has been locally transposed as well as the corresponding adequate minimum wage has locally been enacted.","S1","S1-9 - Adequate wages","AR 22"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","We recommend EFRAG defines “covered by social protection against loss of income” and clarify whether it corresponds to a certain level of protection or threshold to define (which, for example, could be linked to a living wage). ","S1","S1-10 - Social protection","33."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Move this to ESRS 2, this is related to the general statement with regards to the human rights policy.","S1","S1-1 - Policies related to Own workforce","12."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Region is not really defined. This could lead to different approaches in reporting. Why not use countries as in 27b or continents as defined by UN?","S1","S1-7 - Collective bargaining coverage and social dialogue","27. (c)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","More clear to only refer to maternity leave. Open question: the basis to calculate the coverage is then only all female employees? Which would be different basis than calculating the coverage for the other life events.","S1","S1-10 - Social protection","34. (d)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Since a work-related accident inherently involves an injury, distinguishing fatalities by injury and accident in this context is redundant. All accidents are already injuries, so the differentiation does not make sense. Better keep wording from previous standard but just delete fatalities.","S1","S1-13 - Health and Safety metrics","AR 28"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The statement does not belong here and is inconsistent to all other topical standards. The paragraph should be deleted.","S1","S1 - Interaction with other ESRS","10."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","(19 a) “including the approach in situations where tensions arise between such actions and other business pressures” - voluntary DP in original ESRS. Making voluntary DP mandatory goes against aim of simplification. Initial disclosure requirement S1-4 paragraph 41 is sufficient “ whether and how it ensures that its own practices do not cause or contribute to material negative impacts on own workforce”.","S1","S1-3 - Actions and Resources related to Own workforce","19. (a)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree"," Delete subparagraph (b)(iii)","S1","S1-15 - Remuneration metrics","AR 36"]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I agree","The amendments to the requirements on how a company engages with its own workforce streamlined the process","S1","S1-2 - Engagement with own workforce and workers’ representatives, existence of channels for own workers to raise concerns or needs and approaches to remedy","15."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","We disagree as now the \"tension\" description becomes a \"shall\" criteria (initally, it was a \"may\" datapoint). The wording \"where potentially / significant tension arise\" should be added as otherwise it would counteract the intention to simplify the reporting requirements. ","S1","S1-3 - Actions and Resources related to Own workforce","19. (a)"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I disagree","§a) This new formulation does not simplify but complexify our reporting, we would suggest to come back to previous formulation","S1","S1-5 - Characteristics of the undertaking’s employees","23."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","A boolean DP (whether) will complicate the structure of a generic GDR-P. Suggestion: create a separate datapoint in S2-1: \"It shall state whether  policies cover specific groups of value chain workers (e.g. particular age groups or workers in a particular factory or country) or all value chain workers.\"\n\nOr, create an AR to specify content (without a boolean).","S2","S2-1 - Policies related to value chain workers","10."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,null,"The BAK argues that some important nuances are lost as a result of the proposed simplifications: For example, it makes sense to design whistleblowing mechanisms and complaint channels differently, depending on whether they are designed for employees in the value chain, local communities or consumers. These are instruments that must be designed as effectively as possible in the interests of the employees, the other affected parties, but also the companies, because they enable information to be passed on quickly to the company and remedial action can be taken.","S2","",""]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Leverage effects should be eliminated due to weak market position in several sectors","S2","S2-3 - Actions and resources related to value chain workers","AR 6"]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I partially agree and partially disagree","Similar to comment for ESRS 1 Appendix A: the social susubtopics in parenthesis are not exhaustive of the sub-topic title/ human rights instruments mentioned in CSRD. Hence all parentheses should start with 'including'.","S2","S2 - Objective","4."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","The new format makes the disclosure more concise and easier to understand, while avoiding overlaps with ESRS 2. Moving duplicated elements to GDR-A improves consistency across standards. The focus on key actions, mitigation, remediation, and resources ensures clarity.","S2","S2-3 - Actions and resources related to value chain workers","17."]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","Consolidation exercise limits duplication of datapoints to consider during preparation; allows having overarching disclosure and refer to this disclosure in topical chapters\n","S2","S2-3 - Actions and resources related to value chain workers","19."]
["Excels","NomoGaia","NGO","United States",null,null,"I partially agree and partially disagree","Insert “and grievance mechanisms” after “policies” in the first sentence. REASON: For companies’ grievance mechanism, outreach (the process of informing potential claimants of the existence of grievance mechanisms and how to access them) is key. see: https://wrap.warwick.ac.uk/id/eprint/185392/. This supports S2 DR 15 and is an alternative to our suggested change to it. ","S2","S2-2 - Engagement with value chain workers, existence of channels for value chain workers to raise concerns or needs and approaches to remedy.","AR 1"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It would be useful to specify how this can be aligned with the scope of the Corporate Sustainability Due Diligence Directive (CSDDD), in order to ensure consistency between reporting obligations and due diligence requirements across regulatory frameworks.","S2","S2 - Objective","7."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","We recommend slightly revising the wording of this AR, as the phrasing of amended AR 16 was, in our view, clearer. One example of possible redrafting is:\n“Among the policy aspects that can be disclosed, the undertaking can provide an illustration of the types of communication of its policies to those individuals, group of individuals or entities for whom they are relevant, either because they are expected to implement them (for example, the undertaking’s employees, contractors and suppliers), or because they have a direct interest in their implementation (for example, own workers and investors).”\nIn the current writing, starting with the term “channels” may be misleading, as it overlaps with the terminology used in DR S2-2.","S2","S2-1 - Policies related to value chain workers","AR 1"]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I disagree","We propose that high risk sectors for human rights and labour right violations should disclose processes and targets to manage material impacts, risks and opportunities related to value chain workers. If targets do not exist, companies need to explain why. ","S2","S2-4 - Targets related to value chain workers","5."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I partially agree and partially disagree","Inconsistency of severe: The \"severe\" qualifier here has been kept for human rights issues and incidents connected to workers in the value chain. This is inconsistent with S1 and S3. We support having the word \"significant\" as this is an important connection to risk based HRDD. Keeping \"severe\" is important for the ESRS to remain in line with the principle of risk-based due diligence as outlined in the UNGPs.  \n\nInconsistency of \"issues and incidents\" : Why does S2 use the teminology \"issues and incidents\" here where in S1 and S3 it's just HR incidents? We support using the term \"incidents\" and not \"issues\"","S2","S2-3 - Actions and resources related to value chain workers","19."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","It seems metrics are not required within the framework of this standard. Should it be deleted?","S2","S2 - Objective","5."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","§24 was deleted to avoid the burden of a negative statement. However, if there is no engagement as required by §14, a negative statement will still be necessary. Otherwise, the “shall” in §14 will simply be ignored.","S2","S2-2 - Engagement with value chain workers, existence of channels for value chain workers to raise concerns or needs and approaches to remedy.","14."]
["Excels","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","deletion of “severe” leads to difference to SFDR requirement and should therefore be changed again and “severe” should be added, otherwise, extended reporting burden","S2","S2-3 - Actions and resources related to value chain workers","19."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","Whole phrase \"human rights incidents\" should be in bold as it is a separate defined term. ","S2","S2-3 - Actions and resources related to value chain workers","19."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I disagree","Engagement with stakeholders, especially value chain workers, it something that many undertakings can experience as something complex. By removing several of the listed means of engagement (following the phrase \"this shall include...\"), the requirement loses important contextual clarity. Instead of removing these elements, it might be more helpful to revise the wording to \"this can include...\". This would preserve the informative value of the listed approaches without making them mandatory, giving undertakings clearer guidance on how engagement can be conducted and how it may inform decision-making.","S2","S2-2 - Engagement with value chain workers, existence of channels for value chain workers to raise concerns or needs and approaches to remedy.","14."]
["Excels","Finnwatch ry","NGO","Finland",null,null,"I partially agree and partially disagree","The caveat \"subject to privacy regulations\" should be moved to apply to disclosure of details of reported human rights incidents only, not the full DR. The other caveat \"if applicable\" should be removed fully. If incidents have been reported, the fact that such reporting has been done should always be disclosed. The company could also then provide their response to such reports.","S2","S2-3 - Actions and resources related to value chain workers","19."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","In some industries there is no possibility ot have direct engagement with VCWs, this should be amended to allow the engagement be done via proxy / representatives.","S2","S2-2 - Engagement with value chain workers, existence of channels for value chain workers to raise concerns or needs and approaches to remedy.","14."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The distinction between “causation” and “direct linkage” is not clear, as both appear to describe direct causes of impacts. Regarding the sentence “The actions taken by the undertaking differ depending on its connection to the impact (causation, contribution, direct linkage), and how it has identified the actions as appropriate for addressing material impacts,” it is also not clear what the undertaking is expected to report on. Shall the distinction between causation, contribution and direct linkage be reported separately? In the previous version of ESRS the request was “whether the undertaking causes or contributes to a material impact” with “or” that was reflecting an alternative approach rather than the simplified requirement which seems to require three kinds of impact to be disclosed separately. This is not a simplification, therefore we suggest to eliminate the brackets or insert “or.”","S2","S2-3 - Actions and resources related to value chain workers","AR 6"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","noted","S2","S2-1 - Policies related to value chain workers","AR 1"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","noted","S2","S2-2 - Engagement with value chain workers, existence of channels for value chain workers to raise concerns or needs and approaches to remedy.","AR 4"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I agree","Extremely demanding","S2","S2-3 - Actions and resources related to value chain workers","AR 7"]
["Excels","SAIM GmbH","Consultant (including software vendor)","Germany",null,null,"I partially agree and partially disagree","The disclosures related to ESRS 2 General disclosures SBM-3 were deleted completely from\nESRS S2 Workers in the value chain. The potential information loss of this change would be that disclosures about material impacts, risks and opportunities become more generic and have less information about specific stakeholder groups as specifications about the level of granularity of the materiality assessment have been deleted.","S2","S2 - Objective","1."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We suggest to remove this AR, considering that the information has been already deleted from GDR-P.","S2","S2-1 - Policies related to value chain workers","AR 1"]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","We propose to restore the existing para. 34 to provide a more comprehensive overview that also includes actions related to risks and opportunities, and not only those related to impacts","S2","S2-3 - Actions and resources related to value chain workers","18."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","To align with the simplification approach, we suggest reformulating as follows: “if the undertaking engaged directly with workers in the value chain, their legitimate representatives, or with credible proxies that have insight into their situation for the purpose of target-setting and/or tracking performance against those targets, it shall disclose this fact when disclosing in accordance with [Draft] Amended ESRS 2 GDR-T”","S2","S2-4 - Targets related to value chain workers","21."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","NMIG 2 for para. 12\nThe NMIG contain terms that are not defined. For example, in NMIG 2 for para. 12 on the Amended ESRS S2, the terms \"precarious work\" and \"informal workers\" are used without being sufficiently defined. Terms that are only used within the NMIG should also be defined there.","S2","S2-1 - Policies related to value chain workers","12."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","In order to limit boiler plate texts and increase the relevance and readability of the disclosure, we suggest requiring only disclosures if human rights incidents have been reported. Additionally, the amended wording replaces “number of severe human rights [incidents/issues]” with “number of human rights [incidents/issues].” This broadens the scope from substantiated, high-impact cases to potentially all recorded incidents, regardless of severity. It also risks undermining alignment with SFDR PAI Indicator #14, which refers to “identified cases of severe human rights issues and incidents”. We recommend reintroducing the qualifier “severe” to ensure conceptual clarity and consistency.","S2","S2-3 - Actions and resources related to value chain workers","19"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is recommended to add a phrase about \"good faith efforts\" to work with credible proxies/proper representation as representation is not always clear.","S2","S2-4 - Targets related to value chain workers","AR8"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Examples are quite basic and immaterial examples that should be replaced with more sophisticated examples basis Wave 1 definitions of value chain","S2","S2 - Objective","8."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Consolidate ESRS on value chain stakeholders to streamline standardisation, reduce redundancy in data points, and shorten the disclosure requirements, while allowing flexibility in presentation to enable preparers to adapt based on their specific circumstances (value chain workers typically managed by procurement, affected communities by legal teams, and consumers/end-users by sales)","S2","S2 - Objective","1."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","How can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S2","S2-3 - Actions and resources related to value chain workers","18. (a)"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is expected to add specific examples and descriptions regarding \" workers for a ‘downstream’ entity\" for more clarification.","S2","S2 - Objective","8. (b)"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The removal of the term \"severe\" from the disclosure requirements for human rights incidents across all social standards poses significant challenges. Without a clear limitation to the most serious cases, companies may be required to report even minor or less relevant incidents. This broad scope risks undermining the materiality of disclosures and contradicts the objective of simplification. Maintaining a focus on severe human rights incidents is essential to ensure that reporting remains meaningful, proportionate, and aligned with the principles of relevance and faithful representation.","S2","S2-3 - Actions and resources related to value chain workers","19."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,null,"The deletion of information on types of \"affected communities\" is problematic because a more detailed definition is now missing. More detailed information on the \"type of impacts\" has also been deleted: specifically, whether they are widespread/systemic in contexts in which the company operates or whether they are isolated incidents.\nSome parts have been moved to ESRS 2 – here there could be a risk that the specific focus on the \"affected communities\" will be lost due to the shift to the general ESRS 2, e.g. reporting obligations in the area of human rights, which were originally part of ESRS S3-1 (16th), have now been moved to ESRS 2 (GDR-P) and weakened in terms of content.","S3","",""]
["Excels","GKK Partners","Consultant (including software vendor)","Germany",null,null,"I partially agree and partially disagree","Agree with current part-content.\nSuggestion to add, via additional AR, the (also in NMIG) importance of \"accessibilty\".\nVia: \nAR 2:\n\"Accessibility of information is an important aspect of how the \nundertaking communicates its policies towards affected communities. This could \ninclude translating websites or documents, using pictures or graphics in addition \nto text. When disclosing on paragraph 8, if and when adopted, reflecting their \nspecific content, the undertaking should specify concrete exam-\nples of communication channels (e.g.: flyers, newsletters, dedicated websites, social \nmedia or face-to-face interactions). This include information on how the undertaking ensures that those channcels are known and accessible to the sepcific affected community.\"\nA reference to AR 5 for para. 13 might be added.","S3","S3-1 - Policies related to affected communities","AR 1"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We propose retaining former S3 27 (d) on how the undertaking involves stakeholders in ensuring the effectiveness of their grievance mechanisms, in line with GRI 2-25-e.","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","13."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","the removal of the term \"severe\" from the disclosure requirements for human rights incidents across all social standards is particularly concerning. Without a clear limitation to the most serious cases, companies may be required to report even minor or less relevant incidents. This broad scope risks undermining the materiality of disclosures and contradicts the objective of simplification. Maintaining a focus on severe human rights incidents is essential to ensure that reporting remains meaningful, proportionate, and aligned with the principles of relevance and efficiency","S3","S3-3 - Actions and resources related to affected communities","19."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We recommend slightly revising the wording of this AR, as the phrasing of amended AR 11 was, in our view, clear. One example of possible redrafting is:\n“Among the policy aspects that can be disclosed, the undertaking can provide an illustration of the types of communication of its policies to those individuals, group of individuals or entities for whom they are relevant, either because they are expected to implement them (for example, the undertaking’s employees, contractors and suppliers), or because they have a direct interest in their implementation (for example, own workers and investors).”\n\nIn the current writing, starting with the term “channels” may be misleading, as it overlaps with the terminology used in DR S3-2.","S3","S3-1 - Policies related to affected communities","AR 1"]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I agree","Assessing the effectiveness of grievance mechanisms or community engagement channels goes beyond reasonable due diligence expectations and is hardly measurable. Disclosure should focus on the existence, accessibility, and design of such processes, not on their effectiveness assessment.","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","10."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","Regarding \" The actions taken by the undertaking differ depending on its connection to the impact (causation, contribution, direct linkage), and how it has identified the actions as appropriate for addressing material impacts\" it is not clear what the undertaking is expected to report on. Shall the distinction between causation, contribution and direct linkage be reported separately?\nIn the previous version of ESRS the request was \"whether the undertaking causes or contributes to a material impact\" with \"or\" that was reflecting an alternative approach rather than the simplified requirement which seems to require three kind of impact to be disclosed separately. This is not a simplification therefore we suggest to eliminate the brackets or insert \"or\".","S3","S3-3 - Actions and resources related to affected communities","AR 7"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","same comment as per ESRS S1, S2. Since it seems information about channels is important from a social perspective, we would suggest to add this requirement in the ESRS 2 GDR-P","S3","S3-1 - Policies related to affected communities","AR 1"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","I would suggest to add the possibility to bring the S1-2, S2-2 and S3-2 disclosure requirements together, if they are referred to the Speak Up/whistleblowing channel to avoid duplications","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","10."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","At the end of the sentence the following should be added \"and indicate all identified material negative impacts and risks that remained unaddressed by actions during the reporting year\"","S3","S3-3 - Actions and resources related to affected communities","15."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree"," It is stated that paragraph 1 (a)–(d) has now been consolidated into a single paragraph 1. However, the original sub-paragraphs (a) to (d) provided essential guidance on how an undertaking may report on affected communities—for example, how its activities impact these communities and what actions are being taken in response.The revised paragraph 1 now only refers broadly to material risks and opportunities, which removes valuable context. ","S3","S3-1 - Policies related to affected communities",""]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Regarding \" The actions taken by the undertaking differ depending on its connection to the impact (causation, contribution, direct linkage), and how it has identified the actions as appropriate for addressing material impacts\" it is not clear what the undertaking is expected to report on. Shall the distinction between causation, contribution and direct linkage be reported separately?\nIn the previous version of ESRS the request was \"whether the undertaking causes or contributes to a material impact\" with \"or\" that was reflecting an alternative approach rather than the simplified requirement which seems to require three kind of impact to be disclosed separately. This is not a simplification therefore we suggest to eliminate the brackets or insert \"or\" ","S3","S3-3 - Actions and resources related to affected communities","AR 7"]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This paragraph is structurally redundant and substantively problematic. It creates unnecessary complexity by placing a target-setting requirement in a topical standard that is governed entirely by the general standard, ESRS 2 GDR-T. This cross-reference is flawed: The requirement forces the disclosure of specific targets related to value chain workers that often constitute strategic business secrets.","S3","S3-3 - Actions and resources related to affected communities","15."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The objective described in para. 1 of each draft topical ESRS is inconsistent with Draft ESRS 1. The statement about “dependencies when relevant” and “financial effects” should be deleted to make it consistent with ESRS 1.\n\nChange the wording to:\n\n\"When reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS S3 Affected Communities when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, metrics and targets (if in place).\"","S3","S3 - Objective","1."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The FPIC principles encompass situations requiring good faith consultations with the objective of achieving consent of indigenous people and situations requiring their consent. Therefore, we suggest replacing \"their right to\" with \"the principle of\" before the wording \"free, prior and informed consent ('FPIC')\" in the text. FPIC is not a one-size-fits-all concept. Its interpretation varies across jurisdictions, and its implementation must reflect both international norms and domestic legal contexts. ","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","12."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Considering any legal disputes related to  land rights and to the free, prior and informed consent (FPIC) of indigenous peoples when determining human rights incidents can be burdensome.","S3","S3-3 - Actions and resources related to affected communities","AR 9"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The requirement to state actions is clear but what is meant with the term resources (personnel, money, time…)? Definition not clear enough. Maybe keep focus only on key actions related to material topics. Furthermore, how can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S3","S3-3 - Actions and resources related to affected communities","15."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","How can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S3","S3-3 - Actions and resources related to affected communities","16. (a)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Recommend add \"with affected communities, or good faith effort to engage with their legitimate representatives, or with credible proxies\" as this is not always clear.","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","11."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Recommend add \"with affected communities, or good faith effort to engage with their legitimate representatives, or with credible proxies\" as this is not always clear.","S3","S3-4 - Targets related to affected communities","19."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Recommend add \"with affected communities, or good faith effort to engage with their legitimate representatives, or with credible proxies\" as this is not always clear.","S3","S3-4 - Targets related to affected communities","AR 10"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Inconsistent with other Social ESRS, as it states, “shall be consistent with” instead of “shall be read in conjunction with”.","S3","Interactions with other ESRS","7"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","It is unclear why AR8 only covers some of the requirements originally under para 9b and whether omission of other requirements such as the consideration of systemic / widespread risks and incidents are deliberate or an oversight. These are also not covered within ESRS2. ","S3","S3-3 - Actions and resources related to affected communities","AR 8"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Unclear why disclosures relating to positive impacts, risks and opportunities have been removed. As per ESRS2, if a material IRO has been identified then GDR-A should be followed but then removing the requirement from S3 and only retaining explicit reference to negative impacts creates confusion","S3","S3-3 - Actions and resources related to affected communities","16."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Although we are fully aligned to keep reporting of severe human rights incidents as part of the SFDR requirements, it is unclear why these requirements have not been grouped under one section to clarify all Human rights requirements in one place. In addition, it is unclear if general non complinaces with the UNGP has been deliberately removed or if this is an oversight. Further, a clearer definition of what should be considered as a severe human rights incident must be provided to allow comparability e.g. does AR9 include all the incidents that should be reported or is this just an example","S3","S3-3 - Actions and resources related to affected communities","19."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","We ask for clarity related to paragraph 17, which singles out disclosure of key actions to manage only material negative impacts. however the immeditately preceeding paragraph, DR 15, requires disclosure in accordance with GDR-A which requires disclosure of key actions in relation to all material impacts, risks and opportunities. Furthermore, the old paragraph S3-4 DR 32. (c) relating to the dsiclosure of key actions in relation to  positive impacts has been deleted from mandatory and moved to NMIG. Is it the intention of the EFRAG to only keep the disclosures of key actions in relation to material negative impacts related to Affected Communities as a manadatory DR and all key actions in relation to material positive impacts, risks and oppotunities as voluntary? ","S3","S3-3 - Actions and resources related to affected communities","17."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Consolidate the data point on particular policy provisions on preventing and addressing impacts on indigenous peoples with the general description of policies (§8-9) to streamline reporting","S3","S3-1 - Policies related to affected communities","9."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Move the data point (§12) on the consideration of the rights of indigenous peoples in the stakeholder engagement approach to AR, as indigenous peoples are one category of affected communities","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","12."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Reframe the datapoints on the process for engaging with affected communities and how the perspectives of affected communities inform the undertaking's decisions or activities in connection with ESRS 2 SBM-2, while highlighting key information (material IROs); current drafting is overly granular.\n\nProposed wording:\n\"In addition to the general information disclosed under ESRS 2 SBM-2 on interests and views of stakeholders, the undertaking shall provide information on the type of value chain workers, affected communities, consumers and end\u0002users subject to material impacts, the nature of these impacts (i.e., whether they are widespread and systemic, or related to individual incidents), and whether and how the interests and views of these stakeholders inform its decisions or activities aimed at managing the related material topics/sub-topics.\"","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","12."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","When the undertaking has severe human rights incidents, replace “if applicable, disclose these” (overly granular) with “including, where applicable, a description of affected communities”","S3","S3-3 - Actions and resources related to affected communities","19."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","In reference to §21, delete the datapoint on whether and how the undertaking engages directly with affected communities when disclosing in accordance with ESRS 2 GDR-T as it is already adressed in S3-2","S3","S3-4 - Targets related to affected communities","19."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","The clarification should be made more clear; e.g., if a sub-sub-topic (e.g., land-related impacts) is material, shall we really report the whole sub-topic (communities´ economic, social and cultural rights)? In our opinion paragraph 3 should be called \"When a sub-sub-topic (mentioned in parentheses) is material, the undertaking shall report only this sub-sub-topic, not the entire sub-topic.\"","S3","S3-1 - Policies related to affected communities","3."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Why is the sub-sub-topic \"adequate housing and food\" merged? If we don´t have an IRO on food, we can´t report on that","S3","S3-1 - Policies related to affected communities","3."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","The requirement to state actions is clear but what is meant with the term resources (personnel, money, time…)? Definition not clear enough. Maybe keep focus only on key actions related to material topics. Furthermore, how can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S3","S3-3 - Actions and resources related to affected communities","15."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","How can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S3","S3-3 - Actions and resources related to affected communities","16. (a)"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I agree",".","S3","S3-1 - Policies related to affected communities","8."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Recommend add \"with affected communities, or good faith effort to engage with their legitimate representatives, or with credible proxies\" as this is not always clear.","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","11."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,null," (This relates to the whole S3, but S3-2 is most directly relevant) — \n\nthere should be an expectation that communications/engagements with affected communities are conducted in relevant local languages, where applicable. ","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","13."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Recommend add \"with affected communities, or good faith effort to engage with their legitimate representatives, or with credible proxies\" as this is not always clear.","S3","S3-4 - Targets related to affected communities","19."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Recommend add \"with affected communities, or good faith effort to engage with their legitimate representatives, or with credible proxies\" as this is not always clear.","S3","S3-4 - Targets related to affected communities","AR 10"]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","- First, the FPIC principles encompass situations requiring good faith consultations with the objective of achieving consent of indigenous people and situations requiring their consent. Therefore, we suggest replacing \"their right to\" with \"the principle of\" before the wording \"free, prior and informed consent ('FPIC')\" in the text. FPIC is not a one-size-fits-all concept. Its interpretation varies across jurisdictions, and its implementation must reflect both international norms and domestic legal contexts. \n- Second, point (iii) mentions \"legislative or administrative measures that affect them\", which gives to this DR a stricter formulation than art. 6 ILO 169 (“may directly affect”); art. 19 UNDRIP (“may affect”). Companies cannot be expected to consult communities about all government measures that might potentially affect them (e.g., taxes).","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","12."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Here, a uniform assessment of the effectiveness of the channels available to affected communities might be difficult since these processes often dependepen on specific circumstances.","S3","S3-3 - Actions and resources related to affected communities","13."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"(This relates to the whole S3, but S3-2 is most directly relevant) — \n\nthere should be an expectation that communications/engagements with affected communities are conducted in relevant local languages, where applicable. ","S3","S3-2 - Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedy","13."]
["Excels","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The requirement to disclose the annual ratio of the highest paid individual to the median remuneration of employees lacks clarity. It is not clear whether “highest paid individual” refers to an employee or to any person within the undertaking’s own workforce. Published reports show inconsistent reporting practices. This should be clarified to ensure comparability.","S1","S1-15 - Remuneration metrics","44. (b)"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I disagree","§a) This new formulation does not simplify but complexify our reporting, we would suggest to come back to previous formulation","S1","S1-5 - Characteristics of the undertaking’s employees","23."]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree"," The publication of all these indicators shall be limited to employees. The mention to \"other workers\" should be deleted. Indeed the latency between occupational exposure, the onset of the disease, and death makes it impossible to identify deaths due to occupational diseases among subcontractors' employees, as these usually occur several years after the work was performed.","S1","S1-13 - Health and Safety metrics","AR 26"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I disagree","This indicator shall be deleted, it does not provide useful information","S1","S1-15 - Remuneration metrics","44. (b)"]
["Excels","EDF","Preparer (non-financial preparing a sustainability report)","France",null,null,"I disagree","Outside the EEA, the notion often does not exist and is therefore impossible to collect. Therefore  this paragraph could be deleted.","S1","S1-7 - Collective bargaining coverage and social dialogue","27. (c)"]
["Excels","ASD","","",null,null,"I partially agree and partially disagree","Allow to consider information about downstream value chain as classified or sensitive information, therefore allow to apply ESRS 1 section 7.8 (\"The undertaking is not required to disclose classified information or sensitive information, even if such information is considered material\"), whilst maintaining the expectation to conduct reasonable downstream due diligence as practically feasible.","S4","S4-1 - Policies related to consumers and end-users","1."]
["Excels","ASD","","",null,null,"I partially agree and partially disagree","We call to delete S4-2_01 because it is redundant","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","2."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","A boolean DP (whether) will complicate the structure of a generic GDR-P. Suggestion: create a separate datapoint in S4-1:\"It shall state whether  policies cover specific groups (for example, particular age groups) or all consumers and/or end-users.\"\n\nOr, create an AR to specify content (without a boolean).","S4","S4-1 - Policies related to consumers and end-users","9."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","14a) This DP would likely be overlapping with the generic GDR-A content. Transforming it to a AR would allow to include the content in the GDR-A.\n\n\"The undertaking shall describe key actions taken, planned or underway to prevent, mitigate and remediate material negative impacts on consumers and/or end-users, including its approach in situations where tensions arise between such actions and other business pressures (for example, practices related to marketing, sales and data use).\"","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,null,"The BAK argues that some important nuances are lost as a result of the proposed simplifications: For example, it makes sense to design whistleblowing mechanisms and complaint channels differently, depending on whether they are designed for employees in the value chain, local communities or consumers. These are instruments that must be designed as effectively as possible in the interests of the employees, the other affected parties, but also the companies, because they enable information to be passed on quickly to the company and remedial action can be taken.","S4","",""]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Information on the grievance mechnism should be removed from S4-2, as this is addressed in the G-standard. Alternatively, it should be noted in the DR that a reference to the Governance information is sufficient, if there is no separate channel for end-users.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It is recommended not to have this level of granularity to call out marginalized groups","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","11."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","We have concerns about disclosing our feedback loop from customers because sometimes it can involve ongoing litigations. ","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We agree with the first part (how the company engage with customers and how their perspectives inform company's decision or activities to manage impacts) but we disagree with the second part (how the company gains insights into the perspectives of consumers) as we consider this information does not add any value to the reporting. We propose to delete this second part. ","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","11."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We consider additional clarification is required about the type of channels to be disclosed and the information to be reported about each of them. For a big company with B2B and B2C customers as ours, the number and varierty of channels is significantly high and it would require considerable effort.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We consider it would not be necesary the whistleblowing channels to be reported here in order to avoid repetitiveness as they are already covered in ESRS G1.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","AR 3"]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We consider the application of the \"effectiveness criteria for non-judicial grievance mechanisms\" as laid out in the UN Guiding Principles on Business and Human Rights is not possible to all the channels. For example, not possible for the conventional commercial channels (e.g. hotline). So we require additional clarification about how to assess the efectiveness of all the channels reported. ","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","AR 4"]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We consider reporting resources about key actions to manage material IROs could be against competition when tackling consumer topics, so we propose to delete this part. ","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We think the numeration of the Amendments document is wrong from number 14 onwords as there are two number 14. Please, review and renumerate it again correctly in order to avoid confusion (from 15 to 18)","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","We agree with the first part (key actions taken, planned or underway to prevent, mitigate and remediate material negative impacts on consumers and/or end-users) but we disagree with the second part (including its approach in situations where tensions arise between such actions and other business pressures) as we consider this information does not add any value to the reporting. ","S4","S4-3 - Actions and resources related to consumers and end-users","15. (a)"]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We propose this DR to be deleted as we consider it is not reasonable nor feasible for the company to track and assesse the effectiveness of these actions and initiatives in delivering outcomes for consumers and/or end-users. ","S4","S4-3 - Actions and resources related to consumers and end-users","15. (b)"]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","For social standards, the removal of the term \"severe\" from the disclosure requirements for human rights incidents across all social standards is particularly concerning. Without a clear limitation to the most serious cases, companies may be required to report even minor or less relevant incidents. This broad scope risks undermining the materiality of disclosures and contradicts the objective of simplification. Maintaining a focus on severe human rights incidents is essential to ensure that reporting remains meaningful, proportionate, and aligned with the principles of relevance and efficiency. Additionally, we consider the last part of the DR (\"and, if applicable, disclose these\") should be deleted. ","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We propose this DR to be deleted as we consider it should not be necessary to disclose how the company engage with customer to set targets. The way in which the objective is defined does not add any value. Whether or not there is a direct relationship with customers in the definition of objectives does not mean that a company is doing better or worse, nor is it relevant for comparing companies. The only important thing is whether or not there is an objective.","S4","S4-4 - Targets related to consumers and end-users","18."]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I partially agree and partially disagree","Similar to comment for ESRS 1 Appendix A: the social susubtopics in parenthesis are not exhaustive of the sub-topic title/ human rights instruments mentioned in CSRD. Hence all parentheses should start with 'including'.","S4","S4 - Objective","4."]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I partially agree and partially disagree","Former disclosure of whether and how it is ensured that own practices do not cause or contribute to material negative impacts on workers in the value chain has been deleted and should be reinstated. Key part of UNGPs/OECD Guidelines and key issue in what is driving impacts with business partners. 'The undertaking shall disclose whether and how it takes action to avoid causing or contributing to material negative impacts on consumers and/or end-users through its own practices, including, where relevant, in relation to marketing, sales and data use. This may include disclosing what approach is taken when tensions arise between the prevention or mitigation of material negative impacts and other business pressures.'","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","Danish Institute for Human Rights ","NGO","Denmark",null,null,"I partially agree and partially disagree","The disclosure requirement should be expanded to also include metrics in addition to target, to ensure metrics are captured at topical level for S2,S3,S4. Inspiration can be taken from E4-5 including para 21: 'In addition to paragraph 20 and in accordance with [Draft] Amended ESRS 2 GDR-M, the undertaking shall report metrics related to its material impacts on biodiversity and ecosystems.'","S4","S4-4 - Targets related to consumers and end-users","17."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","The new S4-1 is more concise, focusing on the existence and scope of consumer-related policies. Moving detailed commitments and human rights alignment to ESRS 2 reduces redundancy.","S4","S4-1 - Policies related to consumers and end-users","9."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","Combining engagement processes, grievance channels, and remediation avoids duplication and simplifies the disclosure. Moving frequency and type of engagement to NMIG reduces excessive detail.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","10."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","The new S4-3 focuses on key actions and resources for managing IROs, improving clarity. Referring to ESRS 2 GDR-T/GDR-M for effectiveness assessment avoids duplication.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","The revised S4-4 prioritizes disclosure of target definition, performance monitoring, and stakeholder engagement, simplifying reporting. Removing detailed and speculative explanations about lessons learned or improvements reduces burden. Aligning with ESRS 2 GDR-T ensures consistency across disclosures.","S4","S4-4 - Targets related to consumers and end-users","16."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We propose retaining former S4 25 (d) on how the undertaking involves stakeholders in ensuring the effectiveness of their grievance mechanisms, in line with GRI 2-25-e.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","For the purpose of simplification, data points on the availability of channels such as grievance mechanisms from S1, S2, S3 and S4 could be consolidated into one data point covering all categories of stakeholders and moved to ESRS 2. This would be equivalent to the consolidation done for the data point on the human rights policy commitment. This would also increase alignment with GRI 2-25. In addition, the data point could be further aligned verbatim with GRI 2-25-b and e, for greater clarity and interoperability.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","For the purpose of simplification, data points on the general approach to and processes for providing or contributing to remedy from S1, S2, S3 and S4 could be consolidated into one data point covering all categories of stakeholders and moved to ESRS 2. This would be equivalent to the consolidation done for the data point on the human rights policy commitment. This would also increase alignment with GRI 2-25. In addition, the data point could be further aligned verbatim with GRI 2-25-c, for greater clarity and interoperability.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","13."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","We recommend retaining remedy actions (former S4 para 31(b)) as a stand-alone data point, in line with GRI Standard 3-3-d-ii. Having a standalone data point ensures that this information is not overlooked and it is easily identifiable by users and stakeholders.","S4","S4-3 - Actions and resources related to consumers and end-users","15. (a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","the removal of the term \"severe\" from the disclosure requirements for human rights incidents across all social standards is particularly concerning. Without a clear limitation to the most serious cases, companies may be required to report even minor or less relevant incidents. This broad scope risks undermining the materiality of disclosures and contradicts the objective of simplification. Maintaining a focus on severe human rights incidents is essential to ensure that reporting remains meaningful, proportionate, and aligned with the principles of relevance and efficiency.","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Very confusing why previous sub-sub-topics are sometimes moved to extra points and sometimes in brackets. This will lead to huge discussions on which level materiality is going to be defined, whether to use topics in front or in the brackets. Materiality analysis needs to be fully and new implemented due to this change. Only resonable approach: Leave out sub-topics in general and just list the previous sub-sub-topics one after each other. Furthermore, a proper mapping won't be possible like this!!","S4","S4 - Consumers and end-users","4"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Good change from \"Access to (quality) information\" to \"Access to information\" --> more streamlined and clear.","S4","S4 - Consumers and end-users","4.(a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","I understand the requirement to state actions but what is meant with resources (personnel, money, time…)? Definition not clear enough. Maybe keep focus only on key actions related to material topics. Furthermore, how can \"KEY\" actions be identified? Delete the word \"key\".","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Delete the word \"key\".","S4","S4-3 - Actions and resources related to consumers and end-users","15. (a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Move to ESRS 2 like all other human rights related topics.","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The sentence seems off: \"…, or because they have a direct interest in their implementation are examples of policy aspects to disclose.\". What does that mean? Very complex phrasing. Maybe two sentences?","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Please see comment for ESRS S1 para. 21","S4","S4-4 - Targets related to consumers and end-users","17."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Please consider to include this indication only in a general section instead of in each topical standard, because it could be misleading. The same comment is applicable to all S standards.","S4","S4 - Objective","6."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Are commercial-related claims (and the related communication channels implemented with this purpose) raised from customers in the scope of this DR? Or other information are expected to be reported? Please consider to better detail this request for what concerns consumers and end-users.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Regarding \" The actions taken by the undertaking differ depending on its connection to the impact (causation, contribution, direct linkage), and how it has identified the actions as appropriate for addressing material impacts\" it is not clear what the undertaking is expected to report on. Shall the distinction between causation, contribution and direct linkage be reported separately?\nIn the previous version of ESRS the request was \"whether the undertaking causes or contributes to a material impact\" with \"or\" that was reflecting an alternative approach rather than the simplified requirement which seems to require three kind of impact to be disclosed separately. This seems not to be a simplification therefore we suggesto to eliminate the brackets or insert \"or\". ","S4","S4-3 - Actions and resources related to consumers and end-users","AR 6"]
["Excels","UNICEF","NGO","United States",null,null,"I partially agree and partially disagree","It is unclear why this paragraph of ESRS S4 does not reference international human rights instruments in the same way that similar paragraphs do in ESRS S1, S2, and S3. Children are significant consumers and end-users of company products and services, and are especially vulnerable to adverse impacts; therefore, the UN Convention on the Rights of the Child should be referenced. However, consistent with Recital 49 of the CSRD, UNICEF believes the International Bill of Human Rights and other core UN human rights conventions also should be referenced.","S4","S4 - Objective","2."]
["Excels","UNICEF","NGO","United States",null,null,"I disagree","The removal of the term “for example” from the list of economic, social, cultural, civil, and political rights of relevance to ESRS S4 is highly problematic and contradicts one of the core tenets of human rights-based approaches. For example, Principle 18 of the UNGPs states that companies “should include all internationally recognized human rights as a reference point, since enterprises may potentially impact virtually any of these rights.”\n\nBy removing the term “for example”, ESRS S4 becomes a narrower list of sub-topics, creating the risk that companies will use this list as an exhaustive checklist, rather than considering the full range of economic, social, cultural, civil, and political rights relevant to consumers and end-users. There are many examples, but education (UDHR 16), peaceful assembly (UDHR 20), and culture (UDHR 27) are all human rights of relevant to consumers and end-users.\n\nReferencing all potentially relevant human rights, not just a subset, is significant in the context of emphasizing a “fair presentation framework” and entity-specific disclosures, as it provides the full range of potential impacts for companies to consider.","S4","S4 - Objective","4."]
["Excels","UNICEF","NGO","United States",null,null,"I disagree","UNICEF disagrees with the text of ESRS S4 - 7 stating that the unlawful use or misuse of a company’s products and services by consumers and/or end-users should be excluded from this standard. There are many scenarios where unlawful use and misuse are material impacts (e.g., the use of tech-based products to facilitate online child sexual exploitation and abuse), making paragraph is very confusing for companies using the materiality filter. Removing this paragrpah would simplify ESRS S4 for preparers. \n\nCompanies are already publicly addressing the issue of illegal use, and for many tech companies, this will be one of their most material impacts; it is also covered by a variety of EU laws with reporting requirements, such as the EU Digital Services Act. For these reasons, we do not believe it should be left out of a sustainability statement. While the risk of unlawful use or misuse may exist across different sectors, we believe this is especially important for companies operating in the digital environment, and these impacts will no longer be captured by sector-specific standards.","S4","S4 - Objective","7."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I partially agree and partially disagree","It is unclear why the interactions are limited to S1 while the 4 social standards are connected in the Set 1. For instance, the general approach to providing remedies and/or grievance mechanisms is equally relevant to own workforce, consumers, value chain workers, and affected communities. We recommend clarifying these interactions and extending them to ESRS S2 and S3 to reflect this broader applicability (cf. related comment on S2 § 3 and S3 §7).\n","S4","S4 - Interaction with other ESRS","8."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We recommend slightly revising the wording of this AR, as the phrasing of amended AR 13 was, in our view, clearer. One example of possible redrafting is:\n“Among the policy aspects that can be disclosed, the undertaking can provide an illustration of the types of communication of its policies to those individuals, group of individuals or entities for whom they are relevant, either because they are expected to implement them (for example, the undertaking’s employees, contractors and suppliers), or because they have a direct interest in their implementation (for example, own workers and investors).”\n","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","In the exposure drafts, § 14 is assigned twice to two separate datapoints (former § 30 and former § 31). This inconsistency in § numbering continues throughout ESRS S4 and shall be corrected.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","BDO","Auditor","Belgium",null,null,"I partially agree and partially disagree","\"Subject to the relevant privacy regulation\" - This is ambiguous, and requires clarification about whether this statement refers to local privacy regulations or GDPR etc. ","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","Since sub-sub topics were eliminated, it is not clear what is expected to be disclosed about the list of sub-sub topic, now indicated in parenthesis of sub-topics. \nFor example, for ESRS S4: (a) information-related impacts for consumers and/or end-users (privacy, access to information, freedom of expression); ","S4","S4 - Objective","4."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","Please consider to include this indication only in a general section instead of in each topical standard, because it could be misleading. The same comment is applicable to all S standards.","S4","S4 - Objective","6."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","Are commercial-related claims (and the related communication channels implemented with this purpose) raised from customers in the scope of this DR? Or other information are expected to be reported? Please consider to better detail this request for what concerns consumers and end-users","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","Regarding \" The actions taken by the undertaking differ depending on its connection to the impact (causation, contribution, direct linkage), and how it has identified the actions as appropriate for addressing material impacts\" it is not clear what the undertaking is expected to report on. Shall the distinction between causation, contribution and direct linkage be reported separately?\nIn the previous version of ESRS the request was \"whether the undertaking causes or contributes to a material impact\" with \"or\" that was reflecting an alternative approach rather than the simplified requirement which seems to require three kind of impact to be disclosed separately. This seems not to be a simplification therefore we suggesto to eliminate the brackets or insert \"or\". ","S4","S4-3 - Actions and resources related to consumers and end-users","AR 6"]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I disagree","The removal of the term \"severe\" from the disclosure requirements for human rights incidents across all social standards is particularly concerning. Without a clear limitation to the most serious cases, companies may be required to report even minor or less relevant incidents. This broad scope risks undermining the materiality of disclosures and contradicts the objective of simplification. Maintaining a focus on severe human rights incidents is essential to ensure that reporting remains meaningful, proportionate, and aligned with the principles of relevance and efficiency.","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","The currently applicable version (ESRS S4 paragraph 19) specifies that disclosures on engagement with consumers and end-users refer to material impacts on them. In the proposed draft ESRS S4 paragraph 10, this clarification has been removed. In addition, the proposed draft ESRS S4 paragraph 11 refers to actual and potential impacts on consumers and/or end-user, without specifying that this only concerns material impacts. This raises the question of whether section S4-2 is intended to address  engagement more generally, without reference to material impacts. If the intention is to preserve the current meaning, in our view this should be explicitly clarified, confirming that engagement relates specifically to material impacts.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","11."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","Draft AR 2 states that the engagement with consumers and end-users can take different forms, such as information. Whereas, Annex II Acronyms and Glossary of Terms defines stakeholder engagement as an ongoing process of interaction and dialogue between the undertaking and its stakeholders that enables the undertaking to hear, understand and respond to their interests and concerns. It is recommended to harmonise these formulations so that the concept of engagement is applied consistently across the standard.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","AR 2"]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","In our view, companies should disclose the processes through which they support or require the availability of the channels available to consumers and/or end-users to bring their concerns or needs within their business relationships. This would demonstrate whether such mechanisms are applied in practice or remain only formal, and it would allow stakeholders to better assess the effectiveness of due diligence and ethical practices across the company’s broader network.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","it is important to clarify whether and how the ESRS S4 standard applies to B2B companies. In this regard, it would be helpful for the ESRS to provide clear guidance and examples for B2B companies, acknowledging that their “customers” are often other companies. The ESRS should offer straightforward guidance and examples specifically for B2B companies, recognizing that their customers are usually other businesses. To give a complete and accurate overview, ESRS should also let B2B companies report on their impacts, risks, and opportunities related to these business customers, as well as how they address them.","S4","S4 - Objective","1."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","It seems GDR-M does not apply to this standard. Should it be mention here then?","S4","S4 - Objective","5."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","It seems GDR-M does not apply to this standard. Should it be mention here then?","S4","S4 - Objective","5. (b)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We suggest that these disclosure requirements undergo a more comprehensive review, so they fully capture all impacts—positive as well as negative—instead of placing particular emphasis on adverse effects.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","in relation to topics such as privacy, It would be useful to let companies share their entire privacy strategy at once, instead of splitting the information by different affected stakeholder groups (S1-own workforce, S2-workers in the value chain, S4-end users and consumers). This approach would make it easier for companies to describe their overall privacy policies, actions, and targets, and to show how well they are performing on privacy matters.","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nWhen reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS S4 Consumers and end-users, when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, and targets (if in place),  dependencies when relevant, metrics and financial effects\nSuggestion:\nWhen reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS S4 Consumers and end-users, when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, metrics and targets (if in place), dependencies when relevant, metrics and financial effects.","S4","S4 - Objective","1."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nUnnecessary duplication:\nThe undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M. In particular:\n(a) if the undertaking has not adopted policies, actions and targets with reference to a topic related to material impacts, risks and opportunities, it shall disclose this fact;\n(b) the undertaking may present the description of its material impacts, risks and opportunities, in accordance with [Draft] Amended ESRS 2 IRO-2, alongside information about its policies, actions, targets and metrics through which it addresses them, to avoid duplication and support a coherent narrative\nSuggestion:\nThe undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M. In particular:\n(a)\tif the undertaking has not adopted policies, actions and targets with reference to a topic related to material impacts, risks and opportunities, it shall disclose this fact;\n(b)\tthe undertaking may present the description of its material impacts, risks and opportunities, in accordance with [Draft] Amended ESRS 2 IRO-2, alongside information about its policies, actions, targets and metrics through which it addresses them, to avoid duplication and support a coherent narrative .","S4","S4 - Objective","5."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I partially agree and partially disagree","The draft provides for an amendment consolidating DR SX-2 and DR SX-3 from Standards S1 to S4 into a single DR SX-2, in view of the interrelation between the three elements engagement, channels for raising concerns, and remediation. This consolidation would result in the renumbering of all DRs in Standards S1 to S4 by minus one. Such renumbering would entail considerable effort for updating all external and internal documentation and publications. A reduction of this administrative burden would therefore be appropriate.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","10."]
["Excels","Allianz SE","Insurance","Germany",null,null,"I partially agree and partially disagree","The previous paragraph ESRS S4.35 requested the disclosure of only \"severe human rights issues and incidents\". The new paragraph S4.16 extends the scope to the disclosure of \"human rights incidents. In order to ensure consistency (e.g. with SFDR), the word \"severe\" should be reinserted. With regard to the determination of \"severe\" human rights impacts, the definition of the United Nations Guiding Principles on Business and Human Rights should be adopted.","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","EnBW Energie Baden-Württemberg AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","deletion of “severe” leads to difference to SFDR requirement and should therefore be changed again and “severe” should be added, otherwise, extended reporting burden","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","It should also include at least reference to ESRS S2 Workers in the value chain, as they may be end-users of IT systems provided by the undertaking. Also AR 1 for para. 9 refers to suppliers and contactors.","S4","S4 - Objective","8."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","At the end of the sentence the following should be added \"and indicate all identified material negative impacts and risks that remained unaddressed by actions during the reporting year\"","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","Whole phrase \"human rights incidents\" should be in bold as it is a separate defined term. ","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","At the end of the sentence the following should be added \"against each action disclosed under DR G1-2\".","S4","S4-4 - Targets related to consumers and end-users","17."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","\"directly their attention\" should be replaced with \"directly its attention\"","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Reference (old paragraph 17) to the following should still be included: The undertaking shall disclose whether and how its policies with regard to consumers and/or end-users are aligned with internationally recognised instruments relevant to consumers and/or end-users, including United Nations (UN) Guiding Principles on Business and Human Rights.","S4","S4-1 - Policies related to consumers and end-users","9."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","There is no clear definition provided of consumers and end-users.","S4","S4-1 - Policies related to consumers and end-users","9."]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Reference (old paragraph 23) to the following should still be included: The undertaking shall describe the processes it has in place to provide for or cooperate in the remediation of negative impacts on consumers and end-users that the undertaking is connected with, as well as channels available to consumers and end-users to raise concerns and have them addressed.","S4","S4-3 - Actions and resources related to consumers and end-users","13."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Since sub-sub topics were eliminated, it is not clear what is expected to be disclosed about the list of sub-sub topic, now indicated in parenthesis of sub-topics. \nFor example, for ESRS S4: (a) information-related impacts for consumers and/or end-users (privacy, access to information, freedom of expression); ","S4","S4 - Objective","4."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Please consider to include this indication only in a general section instead of in each topical standard, because it could be misleading. The same comment is applicable to all S standards.","S4","S4 - Objective","6."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Are commercial-related claims (and the related communication channels implemented with this purpose) raised from customers in the scope of this DR? Or other information are expected to be reported? Please consider to better detail this request for what concerns consumers and end-users","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Regarding \" The actions taken by the undertaking differ depending on its connection to the impact (causation, contribution, direct linkage), and how it has identified the actions as appropriate for addressing material impacts\" it is not clear what the undertaking is expected to report on. Shall the distinction between causation, contribution and direct linkage be reported separately?\nIn the previous version of ESRS the request was \"whether the undertaking causes or contributes to a\nmaterial impact\" with \"or\" that was reflecting an alternative approach rather than the simplified requirement which seems to require three kind of impact to be disclosed separately. This seems not to be a simplification therefore we suggesto to eliminate the brackets or insert \"or\". ","S4","S4-3 - Actions and resources related to consumers and end-users","AR 6"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The removal of the term \"severe\" from the disclosure requirements for human rights incidents across all social standards is particularly concerning. Without a clear limitation to the most serious cases, companies may be required to report even minor or less relevant incidents. This broad scope risks undermining the materiality of disclosures and contradicts the objective of simplification. Maintaining a focus on severe human rights incidents is essential to ensure that reporting remains meaningful, proportionate, and aligned with the principles of relevance and efficiency.","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I agree","We support the changes proposed.","S4","S4-4 - Targets related to consumers and end-users","4."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Information on the grievance mechnism should be removed from S4-2, as this is addressed in the G-standard. Alternatively, it should be noted in the DR that a reference to the Governance information is sufficient, if there is no separate channel for end-users.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This requirement is overly broad and lacks a clear legal basis in the CSRD, which focuses on customer relationships under governance factors, rather than as a social standard. The expectation to describe policies for all consumers and end-users, including specific groups, risks imposing disproportionate administrative burdens, particularly for companies operating in diverse markets and sectors. Many aspects of consumer and product safety are already strictly regulated by national and EU law, rendering additional reporting redundant and of limited added value.\nFurthermore, the definition of “consumers and end-users” is vague and may lead to inconsistent reporting. The requirement does not sufficiently account for sector-specific differences or the practical limitations companies face in monitoring and managing impacts across all consumer groups.\nThe standard should be limited to material, sector-relevant impacts and aligned with existing legal obligations. Reporting should focus on genuinely material risks and avoid duplicating information already required by law.","S4","S4-1 - Policies related to consumers and end-users","9."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This requirement is overly broad and lacks practical feasibility. The expectation to describe engagement approaches and grievance mechanisms for all consumers and end-users, across potentially global and highly diverse markets, imposes a disproportionate administrative burden — especially for  with indirect or limited contact with end-users. Many aspects of consumer protection, complaint handling, and product safety are already strictly regulated by national and EU law, making additional reporting redundant and of limited added value.\nFurthermore, the definition of “channels” and “remedy” is vague, and the requirement does not sufficiently account for the practical limitations companies face in monitoring and managing concerns across all consumer groups.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","10."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This requirement is overly broad and lacks practical feasibility. Expecting companies to describe all actions taken, planned, or underway to prevent, mitigate, and remediate material negative impacts on consumers and end-users — along with approaches for balancing these actions against business pressures — imposes a disproportionate administrative burden, especially for companies operating in diverse and global markets. Many aspects of consumer protection, marketing, and data use are already strictly regulated by national and EU law, making additional reporting redundant and of limited added value.\nFurthermore, the requirement to track and assess the effectiveness of these actions is vague and does not sufficiently account for sector-specific differences or the practical limitations companies face in monitoring and managing impacts across all consumer groups. The option to omit this disclosure if referenced elsewhere adds complexity and risks inconsistent reporting.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","Confederation of German Employers Associations (BDA)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","This requirement is overly broad and lacks practical clarity. Expecting companies to disclose whether and how they have engaged directly with consumers, end-users, their “legitimate representatives,” or “credible proxies” for target-setting and performance tracking is vague and difficult to operationalize — especially for companies with indirect or large-scale consumer relationships. The terms “legitimate representatives” and “credible proxies” are undefined, risking inconsistent interpretation and reporting across sectors and markets.\nMoreover, the feasibility and relevance of such engagement will vary greatly depending on the business model and sector. For many companies, direct engagement with end-users is not practical or meaningful, and may not yield reliable input for target-setting or performance assessment.\nThe standard should clarify the criteria for identifying legitimate representatives and credible proxies, and limit the requirement to cases where such engagement is both material and feasible. Reporting should focus on objective, material indicators, with engagement results used as supplementary context only where appropriate.","S4","S4-4 - Targets related to consumers and end-users","17."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I partially agree and partially disagree","Draft excludes “unlawful use or misuse” of products. But it does not define where misuse still implies company responsibility (e.g. foreseeable misuse). This creates loopholes. The exclusion is too broad. To close the loophole, the standard should clarify that if misuse is reasonably foreseeable and preventable through product design, labeling, education, or controls, then it still falls under company responsibility.","S4","S4 - Objective","7."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I partially agree and partially disagree","The revised drafting convention counts “shall disclose” datapoints in main body and places methodology in ARs (which are still mandatory methodological guidance but not counted as datapoints). This distinction is subtle and could cause inconsistent recording of required datapoints and confusion for assurance scope (what counts as a disclosure datapoint vs methodology).","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","BDO Poland","Auditor","Poland",null,null,"I partially agree and partially disagree","Para 11 requires explanation of how perspectives of vulnerable groups were gained and mentions “credible proxies”. There is no definition of what counts as a credible proxy, how representativeness is assessed, or how consent/protection of vulnerable respondents is ensured. Auditors will need records demonstrating representativeness and methodology; these are not specified.","S4","S4-1 - Policies related to consumers and end-users","11."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I disagree","AR3 lists types of channels and states whistleblowing mechanisms are included “under certain circumstances” — that wording is ambiguous and could lead to inconsistent inclusion/exclusion of whistleblowing data in consumer reporting. Auditors will need to see policy decisions on inclusion; the standard doesn’t require explaining that decision.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","AR 3"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Why is it an AR and not included directly as a paragraph about channels of communication","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","We agree to merge S4-2 and S4-3. But in pararaph 11 there are a lot of information together. We think it would be clearer to separate the different DP. As example : the part on vulnerable poeple.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","11."]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","We think it would be better to separate the point on the effectiveness of theses channels as it is another DP","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12."]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Not clear concerning the part on policies for protecting individuals. Is it a DP ? If yes, it would be better to put it directly as a paragraph","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","AR 4"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","The first part of the paragraph is coved by GDR-A ? Better to mention it. Or to present it like for targets \"when disclosing in accrodance with GDR-T…\"","S4","S4-3 - Actions and resources related to consumers and end-users","15. (a)"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I disagree","Need to be clarified.","S4","S4-3 - Actions and resources related to consumers and end-users","AR 6"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Good simplification but we could still better articulate the GDR and the addtionnal DP in the DR. In eahc paragraph the good wording would be \"in addition to the information required by GDR-P ou GRDA-A…\". Moreover we think AR should not include additional DP. If it is a DP it should be put in a paragraph of the DR. It is well done in ESRS G1","S4","S4 - Interaction with other ESRS","5."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I disagree","We suggest to remove this AR, considering that the information has been already deleted from GDR-P.","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","We propose to restore the existing para. 31(c) to provide a more comprehensive overview that also includes actions relating to positive impacts, and not only those linked to negative impacts","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","We propose to restore the existing para. 33 to provide a more comprehensive overview that also includes actions related to risks and opportunities, and not only those related to impacts","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The objective described in para. 1 of each draft topical ESRS is inconsistent with Draft ESRS 1. The statement about “dependencies when relevant” and “financial effects” should be deleted to make it consistent with ESRS 1.\n\nChange the wording to:\n\n\"When reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS S4 Consumers and end-users when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, metrics and targets (if in place).\"","S4","S4 - Objective","1."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","ESRS S4 is about consumers/end-users where sustainability impacts arise (e.g., health/safety, access, discrimination). Privacy/data protection risks are managed as part of enterprise operational risk, compliance and ICT/cybersecurity, with established controls, metrics and incident reporting. Treating them as “sustainability” topics blurs scopes and dilutes ESRS’ focus. Adding “privacy” to S4 triggers duplicate narratives and assurance across two regimes (operational risk reporting and ESRS), without improving decision-useful sustainability information. Recommendation: Delete all remaining references to “privacy” from ESRS S4 and the cross-cutting list in ESRS 1, because privacy and data protection are already governed and reported as operational/ICT risks under existing legal and risk frameworks. ESRS should not present these matters as sustainability-related.","S4","S4 - Interaction with other ESRS","4. (a)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Remove parts (a) and (b) and keep the introductory paragraph to avoid unnecessary duplication. Paragraph 5 should read as follows:\n\n\"The undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M.\"","S4","S4 - Objective","5."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","We would like EFRAG to clarify whether the scope of S4 is restricted only to private individuals or does it also include institutional clients/corporates.","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","10."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","The concept of incidents and how to identify them is still unclear. Among Disclosure Requirements, Application Requirements and the Glossary there are several definitions of incidents and confirmed/substantiated incidents. We suggest the best approach would be having specific definitions for each case (e.g. human rights incidents, incidents of corruption and bribery, etc.) and presenting them under the related application requirements. Such definitions would then include detailed explanations of:\na) the scope of the matter (e.g. “discrimination at work on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination, including harassment”); and\nb) the type of instances that trigger the reporting of the corresponding metrics (e.g. “judicial and non-judicial proceedings that have been initiated such as cases before domestic courts, mediation, complaints filed with the National Contact Points for OECD Multinational Enterprises”).\nIn our view the best path to support simplification in relation to point (b) above would be to focus on incidents that have been confirmed through a final decision issued by a court of law or relevant authorities.","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","To align with the simplification approach, we suggest reformulating as follows: “if the undertaking engaged directly with consumers and/or end-users, their legitimate representatives, or with credible proxies that have insight into their situation for the purpose of target-setting and/or tracking performance against those targets, it shall disclose this fact when disclosing in accordance with [Draft] Amended ESRS 2 GDR-T”","S4","S4-4 - Targets related to consumers and end-users","18."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","The added value of this requirement is not apparent, as the information in the sustainability report should be consistent anyway. Either the exact interaction referred to should be clarified, or this paragraph should be deleted.","S4","S4 - Interaction with other ESRS","8."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","NMIG 1 for para. 9\nCommunication channels were removed from MDR-Ps, why bringing them up here introducing additional requirements (even as \"possible elements\")? If the guidelines on how to disclose information on policies are not streamlined in ESRS 2, this will lead to different way of presentation across the standards. Possible solution: streamline in ESRS 2 or eliminate completely.","S4","S4-1 - Policies related to consumers and end-users","9."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL\nThe listing in paragraph 14 appears twice.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","RED FLAG\nPreviously (ESRS S4.35), the focus was only on \"severe human rights issues\". Indicator No. 14 in table III of annex I to Delegated Regulation (EU) 2022/12888 also refers to \"severe human rights issues and incidents\". In order to ensure consistency between the SFDR and the ESRS, the word \"severe\" should be reinserted. With regard to the determination of \"severe\" human rights impacts, the definition of the United Nations Guiding Principles on Business and Human Rights should be adopted.","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","In order to limit boiler plate texts and increase the relevance and readability of the disclosure, we suggest requiring only disclosures if there is no grievance mechanism ","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","It does not require to report key actions taken, planned or underway to cause positive impacts and to manage risks and opportunities. It should also require these actions because this would be critical for undertakings that did not identify material negative impacts.","S4","S4-3 - Actions and resources related to consumers and end-users","14(a)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","In order to limit boiler plate texts and increase the relevance and readability of the disclosure, we suggest requiring only disclosures if human rights incidents have been reported. Additionally, the amended wording replaces “number of severe human rights [incidents/issues]” with “number of human rights [incidents/issues].” This broadens the scope from substantiated, high-impact cases to potentially all recorded incidents, regardless of severity. It also risks undermining alignment with SFDR PAI Indicator #14, which refers to “identified cases of severe human rights issues and incidents”. We recommend reintroducing the qualifier “severe” to ensure conceptual clarity and consistency.","S4","S4-3 - Actions and resources related to consumers and end-users","15"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","In order to limit boiler plate texts and increase the relevance and readability of the disclosure, we suggest requiring only disclosures if there is no grievance mechanism ","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","12"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","It does not require to report key actions taken, planned or underway to cause positive impacts and to manage risks and opportunities. It should also require these actions because this would be critical for undertakings that did not identify material negative impacts.","S4","S4-3 - Actions and resources related to consumers and end-users","14(a)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","In order to limit boiler plate texts and increase the relevance and readability of the disclosure, we suggest requiring only disclosures if human rights incidents have been reported. Additionally, the amended wording replaces “number of severe human rights [incidents/issues]” with “number of human rights [incidents/issues].” This broadens the scope from substantiated, high-impact cases to potentially all recorded incidents, regardless of severity. It also risks undermining alignment with SFDR PAI Indicator #14, which refers to “identified cases of severe human rights issues and incidents”. We recommend reintroducing the qualifier “severe” to ensure conceptual clarity and consistency.","S4","S4-3 - Actions and resources related to consumers and end-users","15"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Very confusing why previous sub-sub-topics are sometimes moved to extra points and sometimes in brackets. This will lead to huge discussions on which level materiality is going to be defined, whether to use topics in front or in the brackets. Materiality analysis needs to be fully and new implemented due to this change. Only resonable approach: Leave out sub-topics in general and just list the previous sub-sub-topics one after each other. Furthermore, a proper mapping won't be possible like this!!","S4","S4 - Consumers and end-users","4"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Good change from \"Access to (quality) information\" to \"Access to information\" --> more streamlined and clear.","S4","S4 - Consumers and end-users","4.(a)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The requirement to state actions is clear but what is meant with the term resources (personnel, money, time…)? Definition not clear enough. Maybe keep focus only on key actions related to material topics. Furthermore, how can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","How can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S4","S4-3 - Actions and resources related to consumers and end-users","15. (a)"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Move to ESRS 2 like all other human rights related topics. Additionally We have concerns about disclosing our feedback loop from customers because sometimes it can involve ongoing litigations. ","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The sentence seems off: \"…, or because they have a direct interest in their implementation are examples of policy aspects to disclose.\". What does that mean? Very complex phrasing. Maybe two sentences?","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is recommended not to have this level of granularity to call out marginalized groups","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","11."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Reframe the datapoints on the process for engaging with consumers and end-users and how the perspectives of consumers and end-users inform the undertaking's decisions or activities in connection with ESRS 2 SBM-2, while highlighting key information (material IROs)\n\nProposed wording:\n\"In addition to the general information disclosed under ESRS 2 SBM-2 on interests and views of stakeholders, the undertaking shall provide information on the type of consumers and end-users subject to material impacts, the nature of these impacts (i.e., whether they are widespread and systemic, or related to individual incidents), and whether and how the interests and views of these stakeholders inform its decisions or activities aimed at managing the related material topics/sub-topics.\"","S4","S4-1 - Policies related to consumers and end-users","11."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","When the undertaking has severe human rights incidents, replace “if applicable, disclose these” (overly granular) with “including, where applicable, a description of affected consumers and/or end-users”","S4","S4-3 - Actions and resources related to consumers and end-users","15."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Delete the datapoint on whether and how the undertaking engages directly with consumers and end-users when disclosing in accordance with ESRS 2 GDR-T as it is already adressed in S4-2","S4","S4-4 - Targets related to consumers and end-users","17."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Very confusing why previous sub-sub-topics are sometimes moved to extra points and sometimes in brackets. This will lead to huge discussions on which level materiality is going to be defined, whether to use topics in front or in the brackets. Materiality analysis needs to be fully and new implemented due to this change. Only resonable approach: Leave out sub-topics in general and just list the previous sub-sub-topics one after each other. Furthermore, a proper mapping won't be possible like this!!","S4","S4 - Consumers and end-users","4"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","Good change from \"Access to (quality) information\" to \"Access to information\" --> more streamlined and clear.","S4","S4 - Consumers and end-users","4.(a)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","The requirement to state actions is clear but what is meant with the term resources (personnel, money, time…)? Definition not clear enough. Maybe keep focus only on key actions related to material topics. Furthermore, how can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","How can \"KEY\" actions be identified? Either delete the word \"key\" or mention in the glossary: \"The company may defined themselves the thresholds for key actions.\" OR \"Key actions are those most relevant for strategy and business modell and are at the heart of the company.\" for example.","S4","S4-3 - Actions and resources related to consumers and end-users","15. (a)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Move to ESRS 2 like all other human rights related topics.","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I partially agree and partially disagree","The sentence seems off: \"…, or because they have a direct interest in their implementation are examples of policy aspects to disclose.\". What does that mean? Very complex phrasing. Maybe two sentences?","S4","S4-1 - Policies related to consumers and end-users","AR 1"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is recommended not to have this level of granularity to call out marginalized groups","S4","S4-2 - Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedy","11."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,null," Recommend adding flexibility for how companies do this","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We have concerns about disclosing our feedback loop from customers because sometimes it can involve ongoing litigations. ","S4","S4-3 - Actions and resources related to consumers and end-users","16."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,null,"Recommend adding flexibility for how companies do this","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","UNESPA (Spanish Association of Insurers and Reinsurers)","Association of financial institutions","Spain",null,null,"I disagree","S4-3 §14(a) (Previously §S4-4 31(a)) does not require to report key actions taken, planned or underway to cause positive impacts and to manage risks and opportunities. It should also require these actions because this would be critical for undertakings that did not identify material negative impacts.","S4","S4-3 - Actions and resources related to consumers and end-users","14."]
["Excels","ASD","","",null,null,"I agree","These discloure requirements have been consolidated: DR on the undertaking's overall approach to prevent, detect, investigate and respond to corruption and bribery incidents; DR on training activities within the undertaking about business conduct. Therefore, we welcome EFRAG proposed changes","G1","G1-2 - Actions related to business conduct","10."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","Include in (current 2c GDR-A): \"training activities within the undertaking on business conduct, including the target audience, frequency and depth of coverage. This shall include the functions and/or roles within the undertaking that are most at risk in respect of corruption and bribery, the percentage of functions and/or roles most at risk within the undertaking in respect of corruption and bribery, as well as...\" This information is not related to Policies. It's a bit odd to see it here, especially since it's the point (c) and not (b) following circumstances for not having anti-corruption and anti-bribery policies.","G1","G1-1 - Policies related to business conduct","8. (c)"]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","The number sequence starts over at 1 in GDR-A, which seems to be a mistake (should be 9?).","G1","G1-2 - Actions related to business conduct","9."]
["Excels","CLEERIT","Consultant (including software vendor)","France",null,null,"I partially agree and partially disagree","Suggested inclusion to support coherence (see related feedback above): \"This shall include the functions and/or roles within the undertaking that are most at risk in respect of corruption and bribery, the percentage of functions and/or roles most at risk within the undertaking in respect of corruption and bribery, as well as...\"\n\nThere seem to be a mistake in the paragraph numbers, this one reads 2c and not 10c in the PDF document.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I partially agree and partially disagree","Disclosures (including the associated ARs) on corporate culture according to Set 1 DA should continue to apply so that stakeholders can get a transparent picture of corporate culture.","G1","G1-1 - Policies related to business conduct","1."]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I partially agree and partially disagree","The provision \"the circumstance when where it has no policies on anticorruption or anti-bribery consistent with the United Nations Convention against Corruption1\" should be supplemented by \"it shall state this and whether it has plans to implement them and the timetable for implementation\". This information was included in Set 1. Since the topic of anti-corruption is important, the BAK believes that it is essential that information on the plans and timetable for the implementation of the policies should continue to be included in the report.","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","Chamber of Labour, Austria","Trade union","Austria",null,null,"I disagree","From the BAK's point of view, the registration of the company in the EU Transparency Register or an equivalent register in another EU country is a mandatory disclosure, as it is also relevant information for other stakeholders (e.g. banks).","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Business sensitive information: Some datapoints lead to the reporting of sensitive/unfavourable information , e.g. disclosures of the undertaking on its risk assessments to identify corruption and bribery (G1-3; AR5) during ongoing investigations.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Disproportionate costs; Legal concerns (Collection of information for this datapoint requires a lot of effort and raises legal concerns especially related to in-direct financial contributions outside of the EU).","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Redundancy or contradictions with other DRs/DPs; Concerns about usefulness/interpretation (1. Information already disclosed in EU Transparency Register as well as in national Transparency Registers (e.g. Germany, USA) and therefore considered redundant. 2. A prioritization of “main topics in lobbying activities” could imply that political activities in one country could be more important or “material” than in another leading to misunderstandings with external stakeholders).","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Data not currently available; Concerns on data reliability (Not consistent with the information provided in the financial statements which does not cover the entire perimeter.)","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Data not currently available; Concerns on data reliability (Not consistent with the information provided in the financial statements which does not cover the entire perimeter.)","G1","G1-6 - Metrics in relation to payment practices","20. (b)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Only the policies for the complaints procedure are adressed in G1-1. In order to bundle the requirements on the complaints procedure, it would be advisable to bundle this reporting requirement together with the reporting requirements of ESRS S1-2, S2-2, S2-3 and S2-4 on the complaints procedure in a separate chapter. This would support the opportunitie to refer to the descriptions under G1 in the S chapters. ","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","The metrics relating to anti-corruption and anti-bribery are comprehensible and ok. When summarizing the sub-sub-topics in the ESRS 1 standard, anti-corruption and anti-bribery, animal welfare and complaints procedures were combined in one Sub-Topic. It is unclear why the topics of animal welfare and complaints procedures no longer appear separately in standard G1. This is an inconsistency between the topic overview in ESRS 1 and the G1 standard that should be rectified (see also comment on ESRS G1 - 8)","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA.","G1","G1-5 - Metrics related to political influence and lobbying activities","15."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA.","G1","G1-6 - Metrics in relation to payment practices","19."]
["Excels","Federation of German Industries (BDI)","Business association (other than association of financial institution)","Germany",null,null,"I disagree","It is recommended to maintain as a voluntary disclosure to avoid unintended legal and agency implications. Requiring legal violation disclosure imposes a new, potentially serious obligation in Europe where no affirmative duty currently exists. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Against simplification. Former AR2 was a may DP and now is mandatory. The rationale of replacing the 2 deleted DPs about the management of relationships with suppliers is not valid because the info required is completely different.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Telefónica, S.A.","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Against simplification. May DP moved to mandatory. We already disclose the number of convictions and amount of fines.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I partially agree and partially disagree","The new version of G1-1 simplifies the requirement by retaining only the minimum mandatory elements, removing the obligation to disclose whistleblowing mechanisms, internal training, and the company’s approach to corporate culture.\nThis simplification reduces the depth of disclosure on ethical practices and organisational integrity, which may limit the perception of a company’s ethical maturity. However, it may ease initial reporting, especially for companies still structuring their conduct policies. Voluntary disclosures could help bridge this gap.","G1","G1-1 - Policies related to business conduct","7."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I partially agree and partially disagree","The new version of G1-2 retains the essential elements on ethical management and supplier relations, while presenting a more streamlined structure focused on concrete actions. It also consolidates information requirements previously covered under G1-3 “Prevention and Detection of Corruption and Bribery”.\nThe exclusion of details on specific policies, such as late payment prevention or separation of investigative functions, may reduce disclosure depth. However, the emphasis on training and ESG integration in the supply chain strengthens the link between business conduct and sustainability, especially for companies with complex value chains.","G1","G1-2 - Actions related to business conduct","10."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I agree","We agree that companies are now required to disclose business conduct targets using the common target reporting model defined in ESRS 2 GDR-T. This includes:\n• Objectives to improve or maintain ethical practices and business behaviour;\n• Associated indicators and timelines, where applicable.\nThe introduction of mandatory business conduct targets is a step forward in accountability and transparency. However, since reporting follows a cross-cutting model (GDR-T), there is a risk that targets may become generic or lack ambition. It is essential to ensure that these targets are clear, relevant, and aligned with the company’s material risks and impacts.","G1","G1-3 - Targets related to business conduct","11."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I partially agree and partially disagree","The new version significantly reduces the depth of required information, shifting from a detailed, multifaceted approach to a focus on two main indicators: convictions and confirmed incidents.\nWhile this simplification may ease reporting and reduce administrative burden, it limits transparency on how companies respond to specific cases. In high-risk sectors, the omission of additional data may undermine stakeholder trust and credibility. Optional disclosures could help maintain confidence.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I partially agree and partially disagree","The new version reduces the level of detail required, removing the obligation to disclose internal responsible parties, transparency platform registrations, and estimates of in-kind contributions. The focus is now on aggregate values and stated lobbying positions.\nThis simplification facilitates reporting but may limit visibility into oversight mechanisms and institutional transparency, particularly in contexts where political influence is sensitive. Encouraging voluntary disclosures could help mitigate this risk.","G1","G1-5 - Metrics related to political influence and lobbying activities","15."]
["Excels","GRACE empresas responsaveis","Business association (other than association of financial institution)","Portugal",null,null,"I partially agree and partially disagree","The new version removes the obligation to report average payment times and the methodology used, focusing only on standard terms and pending legal proceedings.\nWhile this reduces reporting burden, it may hinder the assessment of real impacts on SMEs, especially in sectors where payment delays can have critical consequences. Including optional indicators on payment performance could help maintain transparency and support fair business practices.","G1","G1-6 - Metrics in relation to payment practices","19."]
["Excels","GKK Partners","Consultant (including software vendor)","Germany",null,null,"I agree","Simplified and user-oriented with \"total monetary value\".","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","SAP SE","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","we object the change of the DP for confirmed incidents of corruption (paragraph 14) from may to shall.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","Amended G1 requires reporting information on the protection of whistleblowers (paragraph 8(b)) but lacks a requirement to report on the whistleblowing mechanisms themselves. We propose reinstating former G1 10(a), for alignment with GRI 2-26-a-ii.","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Global Reporting Initiative","Standard setting initiative","Netherlands",null,null,"I partially agree and partially disagree","G1 AR3 should clarify whether 'actors in its upstream and downstream value chain' include also non-employees in the undertaking's own workforce. It is important that incidents involving non-employees are also captured by this DR.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The title of G1-1 should be corrected from 'Business Conduct' to 'Corporate Culture' to accurately reflect its content. It is crucial to structure the ESRS so the materiality assessment can be applied at the subtopic level; otherwise, it forces disclosure on potentially non-material issues. We propose rewording this section to allow for a separate materiality assessment for each individual subtopic. Please also assure that the following datapoints are clearly marked per topic, so that the materiality can be utilised.","G1","G1-1 - Policies related to business conduct","7."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Datapoint 10c on corruption should be grouped with other related disclosures, not absorbed into the general G1 section. This structural change is essential to allow the materiality assessment to function as a proper filter at the subtopic level and to avoid potential conflicts with auditors over the scope of G1 disclosures.  In general, Disclosure Requirement G1-2 combines several thematic areas, not all of which relate directly to the reporting of actions. For instance, information concerning suppliers or processes for handling incidents related to corruption and bribery aligns more closely with the management approach than with the implementation of specific actions. Unlike other standards, where the disclosure of actions remains open and flexible, G1-2 predefines the content to be reported. While this is not necessarily problematic, it may appear somewhat inconsistent in comparison with the structure of other standards.","G1","G1-2 - Actions related to business conduct","10."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is still not clear what is intended for \"comparable position\". The Standard should give clear guidance in order not to over report on comparable positions, as not ll the positions held in public administration have the same relevance (e.g. if someone was in the board of statutory auditors of an hospital is not probably a relevant information).\nFurthermore, a clarification of what is included in the definition of \"public administration\" is critical. Moreover on Datapoint 10c on corruption should be grouped with other related disclosures, not absorbed into the general G1 section. This structural change is essential to allow the materiality assessment to function as a proper filter at the subtopic level and to avoid potential conflicts with auditors over the scope of G1 disclosures. \n\n","G1","G1-5 - Metrics related to political influence and lobbying activities","10."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The input refers to G1-2 Paragraph 2 (c): \n\nConsolidation of different training purposes and activities could be challenging with view to the IRO mapping process, as it fails to clearly indicate which sub-topic G1-2 Paragraph 2 (c) relates to. Therefore, a more distinct division into the sub-topics is necessary. Especially, the disclosure requirement regarding the procurement team should be separated as it refers to the topic management of relationships with suppliers.\n\nThe new wording regarding the members of the administrative, management and supervisory bodies is not clear. Recommendation: Revert to the previous text and include 'the extent to which training is given to'. Alternatively, it should be emphasized that external training is also meant in order to prevent potential conflicts of interest.\n","G1","G1-2 - Actions related to business conduct","7."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The input refers to G1-3 Paragraph 6:\n\nA disclosure requirement regarding the number and nature of confirmed incidents of corruption and bribery is misleading and should be deleted. A high number of incidents seems negative but might also reflect an effective compliance management system with investigation measures in place. \nIn addition, the disclosure requirement contradicts 1. the principle of the presumption of innocence and 2. the principle under German law that offenses do not regularly have to be reported to the authorities, but it is the company's responsibility to adequately address compliance violations within the company.\n","G1","G1-3 - Targets related to business conduct","7."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The input refers to G1-5, AR 7 and 8 for para 16:\n\nRegarding political contributions further differentiation and explanation is needed (the purpose of a contribution as main criteria): \nFinancial or in-kind contributions to external organizations (e.g. lobbyists, charities, think tanks or trade associations) or non-consolidated companies should only be considered, if granted with the purpose of passing it on to a relevant recipient like political parties, their elected representatives or persons seeking political office.\n","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 7"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The scope of the required training-related disclosures has been increased. Previously, reporting was limited to training activities on corruption and bribery. The current scope now covers broader 'business conduct' topics. It is recommended to revert to the original scope, as the expanded requirement may lead to inconsistencies and disproportionate reporting efforts, without necessarily enhancing the relevance or comparability of the information disclosed.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We reccommend to limit the disclosure for individual case of corruption to the top management and not to \"all individuals\", which could be interpreted in a much broader sense. Additionally This adds an additional disclosure requirements for preparers. We believe that the principle of not increasing reporting requirements should be applied consistently. Even if the datapoint itselbf is not technically complex, the change in status to mandatory will require additional interpretation, internal coordination, and alignment with auditors—especially during first-time implementation. This effort should not be underestimated. From our point of view the ESRS revision should refrain from posing any additional effort to preparers.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The requirement to report on \"standard payment terms\" and supplier categorization presents significant practical challenges. The metric lacks clarity in international contexts and provides limited value for understanding supplier relationships. Tracking supplier categories by size would require substantial system changes, while reporting legal proceedings related to late payments without context offers little decision-useful information, especially since material cases are already covered in legal risk reporting. These requirements create unnecessary administrative burden without adding meaningful value to sustainability reporting. We suggest to limit this disclosure to the most relevant countries . ","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","This application requirements is not clearly defined and prone to diverse interpretation, e.g.:\n- \"shall consider\": does this mean that incidents in the upstream/downstream value chain are to be disclosed?\n- what is meant by \"direct involvement\"?\n- does the reporting include information about the \"actors\"?\nIt is unclear to which paragraphs the AR refers to (also AR 4-6). Paragraphs 13/14 do no longer exist in the amended ESRS. Update of references/paragraphs needed.\n","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Considering the EFRAG Explanations January - May 2024 (final version,page 95), the following issues are identified:\n1.\t It focuses solely on first-instance convictions of natural persons, including non-final decisions, leading to a lack of transparency and contradictions with the ECRIS, which only records final convictions.\n2.\tThe CSRD approach lacks transparency by mixing final and non-final convictions. A final conviction has more significance than a non-final decision.\n3.\tTh approach fails to distinguish between the severity of convictions of board members versus employees, and it does not consider cases where the company itself is sanctioned for corruption or bribery, either through criminal proceedings or administrative fines. Relevant national registers for legal entities are disregarded by the CSRD as well. Cases where a company is sanctioned for corruption or bribery are important, as they indicate systemic issues rather than individual excesses.\n4.\tAdditionally, the reliance on information from accused individuals creates reliability issues, as court proceedings often occur years after the offense, and the employees may no longer be with the company. \n5.\tThe focus on payable fines for convictions of natural persons overlooks prison sentences (and their suspension if applicable), which are indicators of the severity of the crime.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","5. (a)"]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","By deleting \"for financai or in kind political contributions\", the requirements seem to suggest that the total monetary calue of financial and in-kind political contributions for \"political influence\" needs to be disclosed. This in turn would increase the reporting burden for companies as it widens the defition of the metrics to be reported to general political influence , while at the same time being open for interpretation. Generally, the collection of information for this datapoint requires a lot of effort and raises legal concerns especially related to in-direct financial contributions outside of the EU, which is why we would suggest to limit the scope from \"global! to \"EU and Member States\" or delete the datapoint. Alternatively, further clarification on the scope needed.","G1","G1-5 - Metrics related to political influence and lobbying activities","8."]
["Excels","European Round Table for Industry","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Suggestion to delete this datapoint as information already disclosed in EU Transparency Register as well as in national Transparency Registers (e.g. Germany, USA) and therefore considered redundant. Additionally, a prioritization of “main topics in lobbying activities” could imply that political activities in one country could be more important or “material” than in another leading to misunderstandings with external stakeholders.","G1","G1-5 - Metrics related to political influence and lobbying activities","9."]
["Excels","REWE Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Remove datapoint or make voluntary - Information gathering for payment practices is connected to high efforts due to unclear methodologies and burdensome data collection. Results will not be comparable. Effort of calculation exceeds the value of information, especially for big groups with de-centralized payment practices.","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","REWE Group","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The definition of “legal proceedings” remains unclear, especially in its interpretation under national law. A clearer concretisation of this term should be in our view accompanied by the inclusion of a well-defined materiality threshold, ideally based on the financial volume of a specific outstanding payment. In our view, this would significantly reduce the reporting burdens.","G1","G1-6 - Metrics in relation to payment practices","20. (b)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We recommend providing a definition of \"political influence\" in the ESRS glossary to ensure shared understanding and comparability in reporting.","G1","G1 - Objective","4. (b)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We recommend providing a definition of \"unfair payment practices\" in the ESRS glossary to ensure shared understanding and comparability in reporting.","G1","G1 - Objective","4. (c)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We welcome the inclusion in NMIG 3 of an illustrative table to present the information on training activities. It could however be specified that the presentation of a separate “executives” category in this table is voluntary.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","If the mandatory nature of the DP related to confirmed incidents of corruption or bribery is confirmed, we recommend providing concrete examples of underlying situations, beyond the definition given in the ESRS glossary, which could be presented in NMIG.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We welcome the inclusion of new definition of \"corruption or bribery convictions\" which would ensure consistency and comparability across undertakings. Nonetheless we recommend clarifying who does “an individual” refer to in such definition (e.g. the undertaking's legal representative or any employee).","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We welcome the inclusion in NMIG 6 of an illustration to present the information on standard payment terms. The following clarifications could, however, be provided: (i) an indication that the breakdown provided by main category of suppliers is mandatory while the breakdown by region is voluntary, (ii) an indication on the fact that the “non-SMEs” category could need to be further disaggregated, depending on the undertaking's specific fact and circumstances and (iii) a reference to a specific number of days in the table instead of the references to “number of days in accordance with current EU regulation” and “number of days depending on legal requirements or specific contractual agreements” (these considerations may be maintained in a footnote).","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","Forvis Mazars Group","Auditor","Belgium",null,null,"I agree","We recommend relying on EFRAG clarifications brought by ID 419 to specify what “currently outstanding legal proceedings” refer to (i.e. \"legal proceedings that have not been legally resolved at year-end\").","G1","G1-6 - Metrics in relation to payment practices","20. (b)"]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I disagree","We propose to keep policies with respect to animal welfare in place.","G1","G1-1 - Policies related to business conduct","1."]
["Excels","Triodos Bank N.V.","Bank","Netherlands",null,null,"I partially agree and partially disagree","Yes, we advocate for transparency on exposure to controversial weapons. As a values-based financial institution, we believe that sustainability reporting must reflect not only environmental and social impacts but also ethical governance practices. ESRS G1-1, which addresses policies related to business conduct, is the appropriate location for disclosures on exposure to controversial weapons, given its alignment with SFDR PAI indicators and its relevance to anti-corruption and ethical standards.\nOur position is grounded in stakeholder expectations and the need for clarity on how financial institutions manage reputational and ethical risks. Transparency on exposure whether direct or indirect is essential for enabling informed decision-making by clients, investors, and civil society. It also supports alignment with international norms, such as the UN Convention against Corruption and the Treaty on the Prohibition of Nuclear Weapons.\n\nWe recommend that ESRS G1-1 explicitly include a datapoint requiring disclosure of policies and screening mechanisms related to controversial weapons. This would ensure consistency with SFDR and reinforce the ESRS framework’s credibility. ","G1","G1-1 - Policies related to business conduct","1."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I agree","Amending Disclosure Requirement  2c (in the adopted ESRS G1 Business conduct 2023), now Disclosure Requirement 4c in the exposure draft, to streamline wording to “political influence and lobbying activities” is a positive change, as it clarifies the focus of the disclosure requirement. Recommendation: Retain wording as included in the amended exposure draft. ","G1","G1 - Objective","4. (c)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Deleting “how it fosters its corporate culture” from Disclosure Requirement  7 in the Exposure Draft 2025 (removes the only Diclosure Requirement on “corporate culture” despite this being an ESRS G1 sub-topic (see “Objective” paragraph 2). Stakeholders need to know how companies foster good corporate culture, which underpins responsible business conduct.\nRecommendation: (1) retain the original wording in Disclosure Requirement 7 (in the aopted ESRS G Business condcut 2023) and (2) clarify in ESRS 2 how reporting companies should disclose information on material topics or sub-topics where there is not a specific policy in place.","G1","G1-1 - Policies related to business conduct","7."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","We understand the rationale for deleting Disclosure Requirement  9 (in the adopted ESRS G1 Business conduct 2023). We do not believe Disclosure Requirement 7 in the Exposure Draft 2025, sufficiently covers this information. In our experience, companies are unlikely to have a specific company policy on “company culture” and therefore may not be prompted to disclose material information if referring to ESRS GDR-P alone. Recommendation: (1) retain the original wording in Disclosure Requirement 9 (in the aopted ESRS G Business condcut 2023)","G1","G1-1 - Policies related to business conduct","7."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Amending Disclosure Requirement 8a in the Exposure Draft 2025 to remove the reference to “whether it has plans to implement them and the timetable for implementation” is concerning because stakeholders need to understand a company’s timetable for implementing critical company policies where not in place.\nRecommendation: (1) retain the original wording in Disclosure Requirement 10 b (in the adopted ESRS G1 Business conduct 2023)  (2) and/or amend ESRS 2 para. 30 (62 amended) to require companies to disclose the timeline for implementation where they do not have the policy in place.","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","The protection of whistleblowers is a G1 Business conduct sub-topic and, therefore, ESRS 2 GDR-PAT disclosures apply. Given the sub-topic's importance, we are, however, concerned that deleting the Disclosure Requirement 10c i. (in the adopted ESRS G1 Business conduct 2023) (whether the company provides training whistleblower reporting channels and to staff receiving reports) and 10 c ii. in the adopted ESRS G1 Business conduct 2023 (measures to protect workers against retaliation) means that companies may omit to report material information. Transparency International’s research shows that 19 EU countries do not comply fully with the EU Whistleblower Protection Directive (link https://www.transparency.org/en/publications/how-well-do-eu-countries-protect-whistleblowers-speakup) and, therefore, specific DRs on companies’ actions to operationalise their whistleblowing channel and protect whistleblowers from retaliation are critical to ensure companies are supporting and encouraging workers to raise concerns.\nRecommendation: (1) retain the orginal wording in Disclosure Requirement 10 (c) i. and ii. (in the adopted ESRS G1 Business conduct 2023), and/or (2) include ARs that set out what companies should disclose on whistleblowing channels and whistleblower protection from retaliation.","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Amending Disclosure Requirement 8b in the Exposure Draft 2025 to remove the reference to “whether it has plans to implement them and the timetable for implementation” is concerning because it is unclear whether this information would be required through GDR-PAT as the company does not already have a policy in place. Stakeholders need to understand a company’s timetable for implementing critical company policies if they are not already in place. Protecting whistleblowers is critical for encouraging workers and third parties to raise concerns. \nRecommendation: (1) retain orignial Disclosure Requirement 10 d)( in the adopted ESRS G1 Business Conduct 2023) (2) and/or amend ESRS 2 paragraph 30. (62 amended) to require companies to disclose the timeline for implementation where they do not have a policy in place.","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","We acknowledge that EFRAG have kept the protection of whistleblowers as part of the sub-topics in G1 Business conduct, and because of this, the ESRS 2 GDR-PAT applies, which we welcome. However, the deletion of 10 e (in the adopted ESRS G1 Business conduct 2023) removes the requirement for companies to disclose whether the company has the procedures in place to investigate incidents and whistleblower reports promptly, independently, and objectively. This aspect may be overlooked by reporting companies without a specific reference in the topic disclosures. Stakeholders need to know that companies have the appropriate procedures in place to act on whistleblower reports to ensure both internal and external trust in the company.\nRecommendation: (1) retain orignal Disclosure Requirement 10 e) wording (in the adopted ESRS G1 Business conduct 2023), or (2) include ARs that set out what companies should disclose on their procedures for investigating reports by whistleblowers promptly, independently and objectively. ","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Deleting Diclosure Requirement 18 b (in the adopted ESRS G1 Business conduct 2023) on whether the reporting company separates investigators or the investigating committee from management during investigations would remove material information on the company’s anti-corruption and anti-bribery IROs. The independence of investigators from the team under investigation is crucial for ensuring an impartial investigation and to remove conflicts of interest. \nRecommendation: 1) retain Disclosure Requirement 18 (b) wording (in the adopted ESRS G1 Business conduct), or (2) include ARs that set out what companies disclose in reference to anti-corruption and anti-bribery investigations.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Deleting Disclosure Requirement 18 c (in the adopted ESRS G1 Business conduct 2023), means the company may omit explaining how it ensures findings from investigations, and outcomes, are reported upwards to senior leadership, which is essential if findings are to be acted upon and inform remediation.\nRecommendation: 1) retain Disclosure Requirement 18 (c) (in the adopted ESRS G1 Business conduct) wording, or (2) include ARs that set out what companies should disclose in reference to the procedures for reporting the outcomes of investigations.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Deleting Disclosure Requirement 19 (in the adopted ESRS G1 Business conduct 2023)removes the requirement to disclose plans to adopt procedures to prevent, detect, and address allegations or incidents of corruption and bribery. It is unclear how the ESRS 2 GDR-PAT architecture applies where there is no policy and/or procedure in place.\nRecommendation: Amend ESRS 2 paragraph 30. (62 amended) to require companies to disclose their plans and timeline for implementing policies or procedures where these are not in place.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","Amending Disclosure Requirement 20 (in the adopted ESRS G1 Business conduct 2023) from a mandatory to voluntary disclosure (to be included in the Non-Mandatory Illustrative Guidance) weakens this Disclosure Requirement.. Stakeholders need to know that companies are communicating their policy commitments in an accessible way and to check that commitments are understood.\nRecommendation: (1) retain orinigal wording from Disclosure Requirement 20 (in the adopted ESRS G1 Business conduct 2023), or (2) include ARs that reference what companies should disclose in reference to the communication of anti-bribery and anti-corruption policies.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I agree","We welcome the move to make new Disclosure Requirement 10 c mandatory and the recognition of the importance of training for high-risk teams, such as procurement. Sales and business development teams are all higher risk\nRecommendation: Retain wording as included in the amended Exposure Draft 2025 in new Disclosure Requirement 10 c.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I agree","We welcome the amendment to make the new Disclosure Requirement 14 mandatory and appreciate that EFRAG recognised the gap that would have resulted from deleting DR 22. Without this change, there would have been no mandatory Disclosure Requirements on confirmed incidents. It is essential that at least one DR addresses confirmed incidents.\nRecommendation: Retain wording included in the amended Exposure Draft 2025 in new DR 14.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","We are concerned that moving Disclosure Requirement  25 b), 25c) and 25 d) (in the adopted ESRS G1 Business conduct 2023) to the NMIG may lead to these Disclosure Requirements being overlooked. Stakeholders need to have transparency on the action taken by companies on corruption incidents. While we recognise that these Disclosure Requirements were voluntary in ESRS G1 Business conduct, as Disclosure Requirement 25 (a) (in the adopted ESRS G1 Business condcut 2023) now Dirclosure requirement 14 has been moved to mandatory content in the amended Exposure Draft 2025, we see this as an opportunity to consider moving Disclosure Requirements 25 b), 25 c), and 25 d) (in the adopted ESRS G 1 Business conduct 2023) to mandatory. \nRecommendation: (1) Review Disclosure Requirements 25 (b), 25 (c), and 25 (d) and consider including in mandatory content. (2) and/or include application requirements for amended DR 14 to include information relating to corrective actions. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I agree","We welcome the amendment to Disclosure Requirement 16 as it has provided clarity to the diclosure by create a disctinction between DPs for political influence and lobbying actitivtes. ","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I agree","We welcome the amendment to Disclosure Requirement 17 as it has provided clarity to the diclosure by create a disctinction between DPs for political influence and lobbying actitivtes. ","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Transparency International UK ","NGO","United Kingdom",null,null,"I disagree","We think that deleting Disclosure Requirement 10 d) (in the adopted ESRS G1 Business conduct)will make it more difficult to easily cross-reference information included in the relevant transparency registers.  We do not believe this would be onerous information to disclose.\nRecommendation:  1) retain original wording in the adopted ESRS G1 Business conduct 2023 wording, 2) and/or include information previously included in an application requirement for new DR 17. ","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Austrian Financial Reporting Advisory Committee (AFRAC) ","(National) standard setter","Austria",null,null,"I partially agree and partially disagree","From a G1-perspective, summing up former G1-2, G1-3, and partially G1-4 under new G1-2 seems to reduce datapoints while rather mixing up different contents under one datapoint. This might impede clarity, readability, and comparability of ESRS reports.","G1","G1-2 - Actions related to business conduct","10."]
["Excels","Henkel AG & Co. KGaA","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","\"Standard payment terms\" do not exist in an international context; \"category of suppliers\" is not defined since it can not be defined across companies; hence, the data point should be deleted","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG provide a definition of political influence, by leveraging on the definition of direct/indirect political contributions given in ARs 7 and 8, to ensure clear distinction with lobbying activities.","G1","G1 - Objective","4. (b)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG provide a definition of unfair payment practices, this concept being newly introduced in the ED.","G1","G1 - Objective","4. (c)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG provide a definition of “management of relationships with suppliers” which is a large concept. Related NMIG could be supplemented with practical examples such as (i) implementation of a department dedicated to purchases and supplier relationships or (ii) inclusion of policies in clauses of contracts signed with suppliers, in order to enlarge their scope to value chain, with clear references to the information included in the sustainability statement on the related policies.","G1","G1-2 - Actions related to business conduct","10. (a)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG provide a definition of “depth of coverage” and clarifies whether it relates to percentage of trained people or it refers to the level of training (e.g. basic, advanced or expert). \nBesides, as training activities on business conduct cover very large set of trainings, clarifying the nature of the training activities covered by this DP could be useful.\nWe recommend also that EFRAG clarify whether this DP requires to disclose the percentage of members of the administrative, management and supervisory board who received business conduct training. \nFinally and with respect to NMIG 3 that provides an illustration for disclosing information on training activities, we encourage specifying that the presentation of a separate “executives” category within this illustrative table is voluntary. ","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We suggest that EFRAG provide concrete examples of “confirmed incidents” of corruption or bribery, beyond the definition given in the ESRS glossary, to facilitate the identification by the undertaking of the relevant underlying situations. These examples could be included in NMIG in order not to burden the standard.\nWe recommend also that EFRAG transfer NMIG’s following precision into § 14 of the standard: \"This includes cases that were initiated in previous years where the outcome was only established in the current reporting period.\". At this stage, the wording of this § allows not to report such cases, even though they were also not disclosed the year they were initiated. Such cases could therefore never be reported by an undertaking in its sustainability statement.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG clarify the scope of people directly involved in incidents of corruption or bribery to be considered as AR 3 refers to “employees” while NMIG 4 refers to “own workers” (i.e. including non-employees). ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","We recommend that EFRAG clarify who does “an individual” refer to in the definition of “corruption or bribery convictions” (e.g. the undertaking's legal representative or any employee directly involved as specified in AR 3).\nBesides, there is a discrepancy in AR 4 between the wording included in ESRS G1 ED and the wording included in ESRS G1 log of amendments. The wording included in log of amendments includes the following content which is not in the ED: “In this context, final decisions include all the decisions in the reporting year while awaiting the outcome of a possible appeal. The reporting undertaking may provide additional information if an appeal is considered, has been lodged or was successful.” This clarification is key to know how to consider the situations where an appeal is pending when reporting under § 13 and/or § 14 of ESRS G1. We thereof recommend adding such clarification in AR 4.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","The new definition of fines provided in AR 5 limits the information to be disclosed to the fines “paid to a public treasury”. We recommend that EFRAG clarifies whether fines that comply with the applicable definition but which are paid to other bodies shall be considered  in reporting under § 13.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 5"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG provide a definition of “entrusted power” which is mentioned in corruption definition that is included in the ESRS glossary.\nBesides and considering the fact that the definition of corruption includes fraud incidents, we recommend that EFRAG provide illustration of frauds that correspond to corruption incidents and clarify whether the two following situations are in scope of § 13: \n-\taccounting manipulation\n-\tenvironmental pollution incident with corruption of agent involved in the investigation","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 6"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I partially agree and partially disagree","Former AR 14 “In meeting the requirement in paragraph 29(c) the undertaking shall consider the alignment between its public statements on its material impacts, risks and opportunities and its lobbying activities\" has been moved to NMIG. This AR was considered useful as reconciling double materiality assessment with lobbying activities of the undertaking. Therefore, we recommend EFRAG transfer this guidance to the standard.\nBesides, we note that former § 29d) related to registration in the EU Transparency Register or in an equivalent transparency register in a Member State has been removed from the standard even if the related information was not complex to provide. Similarly,  existence of a Public Affairs department withing the organization is one example of information on lobbying activities that has been disclosed in 2024 ESRS sustainability statements. Therefore, we recommend that EFRAG include in NMIG in relation to § 17   examples of information to provide regarding lobbying activities such as (i) registration in the EU Transparency Register or in an equivalent transparency register in a Member State or (ii) existence of a Public Affairs department.","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG clarifies whether the undertaking is required to report information related to SMEs under this § even if SMEs transactions are not material compared to the total transactions made with suppliers  . We also recommend that EFRAG define “SME”.\nWe also recommend that EFRAG clarify how the percentage of payment aligned with standard terms shall be computed i.e.: \n-\ton the basis of the number of invoices or the total amount of invoices;\n-\ton the basis of the payments made during the reporting period even if the invoice was received or dated during a previous reporting period.\nWith respect to the illustration given in NMIG 6, we recommend specifying that the breakdown provided by main category of suppliers is mandatory while the breakdown by region is voluntary and that the undertaking could consider further disaggregating the “non-SMEs” category depending on its specific facts and circumstances. \nWe finally recommend replacing in the table the references to “number of days in accordance with…” or “number of days depending on…” by a given illustrative number of days (this may be specified in a footnote to explain how the figure has been calculated).","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","Compagnie Nationale des Commissaires aux Comptes","Auditor","France",null,null,"I agree","We recommend that EFRAG clarify whether investigations of government authorities on the undertaking’s payment practices are to be considered as “legal proceedings currently outstanding for late payments”.\nClarifications brought by ID 419 could be usefully added to specify what “currently outstanding legal proceedings”  refer to (i.e. “legal proceedings that have not been legally resolved at year-end”) and whether proceedings initiated and closed during the reporting period shall also be considered.","G1","G1-6 - Metrics in relation to payment practices","20. (b)"]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","We reccommend to limit the disclosure for individual case of corruption to the top management and not to \"all individuals\", which could be interpreted in a much broader sense.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","It is still not clear what is intended for \"comparable position\". The Standard should give clear guidance in order not to over report on comparable positions, as not ll the positions held in public administration have the same relevance (e.g. if someone was in the board of statutory auditors of an hospital is not probably a relevant information).\nFurthermore, a clarification of what is included in the definition of \"public administration\" is critical. The concept of lobbyng shouldi be better clarified","G1","G1-5 - Metrics related to political influence and lobbying activities","10."]
["Excels","Confindustria","Business association (other than association of financial institution)","Italy",null,null,"I partially agree and partially disagree","It is still very difficult to calculate the percentage of payment practices aligned with the payment standard terms, especially for companies operating in several different countries. We suggest to limit this disclosure to the most relevant countries. ","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","Equinor ASA","Preparer (non-financial preparing a sustainability report)","Norway",null,null,"I disagree","While we support transparency on anti-corruption performance, we remain concerned that obliging disclosure of “confirmed incidents” may lead to:\n•\tRisk self-incrimination – Requiring publication of internally confirmed violations that have not been tested by a court could place companies in a problematic position, threatening the important and fundamental protection against self-incrimination.\n•\tUndermine the presumption of innocence – An internal conclusion is not equivalent to a court conviction, and disclosure could prejudice ongoing or potential cases. \n•\tCreate uneven or misleading data – Firms with robust internal controls may appear to have “more incidents” simply because they detect and investigate them thoroughly, not because they have higher exposure to corruption or bribery risks. This is highly-sensitive, context-dependent (Comparing “total number” across firms can be misleading without normalization), and difficult to standardize, which undermines its reliability and comparability, and hence not value adding information to the external stakeholder.\nGiven these issues, our preference remains to retain paragraph 14 as a voluntary disclosure. If it is kept as mandatory, If retained as mandatory, we recommend narrowing its scope to avoid an obligation to also report the type of corruption and bribery where the company does not risk legal liability.  ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","The draft paragraph 10(a) refers to actions taken in relation to relationships with suppliers. However, the draft paragraph appears to suggest that even if another sub-topic (different from management of relationships with suppliers, including (unfair) payment practices) is identified as material, it would still have to be disclosed. In our view, this requires clarification.\nA clear distinction should be made between the different material sub-topics under ESRS G1 and the corresponding datapoints in G1-2. For example, this could be further specified in the section Mapping of sub-topics to disclosures in topical standards.","G1","G1-2 - Actions related to business conduct","10. (a)"]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","The draft paragraph 10(b) refers to actions taken in relation to corruption and bribery. However, the draft paragraph appears to suggest that even if another sub-topic (different from corporate culture which includes anti-corruption and bribery) is identified as material, it would still have to be disclosed. In our view, this requires clarification.\nA clear distinction should be made between the different material sub-topics under ESRS G1 and the corresponding datapoints in G1-2. For example, this could be further specified in the Mapping of sub-topics to disclosures in topical standards.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","UHY ECA Audyt Sp. z o.o.","Auditor","Poland",null,null,"I partially agree and partially disagree","The draft paragraph 10(c) refers to training activities on business conduct. The subsequent part of this paragraph concerns disclosure of whether the procurement team is involved in training related to its engagement with suppliers for the improvement of their sustainability performance. The whole paragraph as currently drafted seems to imply that even if another sub-topic (different from the management of relationships with suppliers, including (unfair) payment practices) is identified as material, it would nevertheless have to be disclosed. In our view, this requires clarification.\nA clear distinction should be made between the different material sub-topics under ESRS G1 and the corresponding datapoints in G1-2. For example, this could be further specified in the Mapping of sub-topics to disclosures in topical standards.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","should fair competition be added here, as an important part of corporarte culture?","G1","G1 - Objective","4. (a)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","The management of relationships with suppliers and (unfair) payment should be recognized as different sub-topics. They may or not be always interrelated. IROs could be linked to the management of relationships with suppliers, (unfair) payments practices, or both. It should be helpful to clarify this point:\n\nb) the management of relationships with suppliers; (unfair) payments;","G1","G1 - Objective","4. (b)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","Should GDR-M be also mentioned here?","G1","G1 - Objective","6."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","to be added: \"if applicable, the circumstance when it has....\"","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","to be added: \"if applicable, the circumstance when it has....\"","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","should this requirement be included under a \"Policy\" related requirement? Additionally, should this apply depending on the results of the materiality assessment? (whether or not corruption and bribery result material). Finally, we would also suggest to clarify \"the functions and/or roles and/or units/departments","G1","G1-1 - Policies related to business conduct","8. (c)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","To be considered the possibility to refer to units/departments","G1","G1-1 - Policies related to business conduct","AR 2"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","We recommend incorporating these requirements into the standards, along with the engagement disclosure requirements (S1, S2, S3, S4), so that organizations can present their approach in a comprehensive and integrated manner.\nAdditionally, it could cause confusion as in ESRS S1, S2, S3, S4 the following is mentioned:\n \nIf the undertaking has policies for protecting individuals that use these channels against retaliation and they are disclosed in [Draft] Amended ESRS G1-1, it may refer to that disclosure. \n\nNevertheless, apparently this is not mentioned in this standard (G1).","G1","G1-2 - Actions related to business conduct","9."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I partially agree and partially disagree","Please add \"where applicable, depending on the DMA results\"","G1","G1-2 - Actions related to business conduct","10."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Proposal:\n(21(a) amended) training activities within the undertaking , including the target audience, frequency and depth of coverage:\n\ti. on business conduct\n\tii. on anti-corruption and anti-bribery\n\tii. whether the procurement team is involved in training related to its engagement with suppliers for the improvement of their sustainability performance. \n\n\nThe following to be moved to metrics:\n This shall include the (former 21(b) amended and former 21(c)) percentage of functions and/or roles most at risk within the undertaking in respect of corruption and bribery, as well as members of the administrative, management and supervisory board.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","I would suggest to move here reporting requirements in relation to:\n-  the number and percentage of employee trainned (including business conduct, anti-corruption and anti-bribery training, procurement, etc)\n - percentage of functions and/or roles and/or departments/units most at risks.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","i would suggest to align this disclosure requirements with the ones requested by GRI 205-4 . Total number and nature of confirmed incidents of corruption.\nb. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.\nc. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.\nd. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","13."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Why this DP is considered as a metric?we would suggest to move it","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Amadeus IT Group, S.A","Preparer (non-financial preparing a sustainability report)","Spain",null,null,"I disagree","Why this DP is considered as a metric? we would suggest to move it","G1","G1-5 - Metrics related to political influence and lobbying activities","18."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nWhen reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS G1 Business Conduct, when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, and targets (if in place),  dependencies when relevant, metrics and financial effects\nSuggestion:\nWhen reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS G1 Business Conduct, when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, metrics and targets (if in place), dependencies when relevant, metrics and financial effects.","G1","G1 - Objective","1."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Problem:\nUnnecessary duplication:\nThe undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M. In particular:\n(a) if the undertaking has not adopted policies, actions and targets with reference to a topic related to material impacts, risks and opportunities, it shall disclose this fact;\n(b) the undertaking may present the description of its material impacts, risks and opportunities, in accordance with [Draft] Amended ESRS 2 IRO-2, alongside information about its policies, actions, targets and metrics through which it addresses them, to avoid duplication and support a coherent narrative\nSuggestion:\nThe undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M. In particular:\n(a)\tif the undertaking has not adopted policies, actions and targets with reference to a topic related to material impacts, risks and opportunities, it shall disclose this fact;\n(b)\tthe undertaking may present the description of its material impacts, risks and opportunities, in accordance with [Draft] Amended ESRS 2 IRO-2, alongside information about its policies, actions, targets and metrics through which it addresses them, to avoid duplication and support a coherent narrative .","G1","G1 - Objective","5."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Why is “(unfair)” placed in brackets? Depending on the intended meaning, either remove the brackets or delete “(unfair)” entirely.","G1","G1 - Objective","4. (b)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Paragraphs counting is flawed\n\nStarting with DR G1-2 the numbering of paragraphs starts with 1 again instead of continuing the count of the paragraph which should read 9 and then the numbering should be continued","G1","G1 - Objective","2."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Why is this paragraph needed? Is this not sufficiently covered in ESRS 2, Paragraph 30?\n\nSince former S1- to S4 requirements were moved into the new ESRS 2, Paragraph 35 the question arises if for ESRS G1, Paragraph the same logic should apply.\n\nEither way, the approach should be consistent across ESRS","G1","G1-1 - Policies related to business conduct","8."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Paragraph 2 (c), last sentence related to DR G1-2, which should actually read 10 (c)\n\nThe whole approach to supply chain management requires reconsideration. On the one hand, supply chain components are inherent in each of the E, S and G standards, whereas ESRS G1 seems to suggest that this is a component of G. It could also be argued that it is most appropriate to reflect supply chain management in the section on General information because the supply chain is often managed across E, S and G in which case it would be most appropriate to reflect this in the General information section. If fair presentation should be the overarching principle, it should be considered if the last sentence in Paragraph 2(c) actually should belong here","G1","G1-2 - Actions related to business conduct","2."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","It is proposed that the data point “(10(c) continued) It shall also disclose whether the procurement team is involved in training related to its engagement with suppliers for the improvement of their sustainability performance,” currently a voluntary data point in the Annex, be amended to become a mandatory disclosure in order to replace the two deleted data points relating to supplier relationships. For reasons of consistency, it would appear appropriate to establish a separate metrics section on supplier management. Furthermore, additional background information would be desirable as to why the substantively new topic of training in supplier engagement is to be included.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Why is the addition during the reporting period needed? Is it not clear from ESRS 2 that all disclosures made refer to the reporting period? Please check all ESRS in this respect","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 1"]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","Change back to “may” instead of “shall” for the number of confirmed incidents of corruption or bribery.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","German Banking Industry Committee (GBIC)","Association of financial institutions","Germany",null,null,"I disagree","There is an inconsistency between Paragraph 11 and 12. If the objective is to understand late payments to SMEs as indicated in Paragraph the disclosure requirements in Paragraph 12 do not achieve this objective.","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","Allianz SE","Insurance","Germany",null,null,"I disagree","Strongly disagree; this is an additional mandatory disclosure requirement and not a simplification","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Allianz SE","Insurance","Germany",null,null,"I disagree","The definitions do not match and shed more confusion then they would help","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Allianz SE","Insurance","Germany",null,null,"I partially agree and partially disagree","Keep the term 'in brief' as it prevents unlimited elaboration. Removing it could lead to unnecessary discussions with the auditors","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Ferring Pharmaceuticals","Preparer (non-financial preparing a sustainability report)","Switzerland",null,null,"I partially agree and partially disagree","It is not clear whether you are looking for the percentage of the roles most at risk who conduct training - or the percentage of empoyees overall who are at risk of corruption and bribery. We have assumed the first because its under training, but it is not clear.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","Reference to ESRS 2 should be 29 to 32, instead of 29 to 31.","G1","G1 - Objective","5."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","\"Metrics\" should be put in bold.","G1","G1 - Objective","5. (b)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","Bold should be removed from \"protection of whistle-blowers\" as it is not defined in annex 2.","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","It is not enough to state that the undertaking is subject to legal requirements. The undertaking should state if it have implemented those legal requirements.","G1","G1 - Interaction with other ESRS","AR 1"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","Bold should be removed from \"animal welfare\" as it is not defined in annex 2.","G1","G1 - Objective","4. (a)"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","At the end of the sentence the following should be added \"against each action disclosed under DR G1-2\".","G1","G1-3 - Targets related to business conduct","11."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","At the end of the sentence the following should be added \"and indicate all identified material negative impacts and risks that remained unaddressed by actions during the reporting year\"","G1","G1-2 - Actions related to business conduct","9."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The current wording may imit disclosures to convictions only in the EU. The following sentence should be added \"The above considerations should be applied, with due consideration of differences, with respect to convictions issued outside of the EU.\"","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I agree","Bold should be put on \"material impacts, risks [] oportunities\".","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Polish Association of Listed Companies","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The percentage should be clarified to ensure more comparable reporting. The percentage should relate to both value and number of payments aligned with these standard terms. The sentence should be rephrased as following: \"a description of the undertaking’s standard payment terms in number of days by main category of suppliers, including SME’s, and the percentage of its payments aligned with these standard terms by value and number of payments; and\"","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","We do understand the wish for an example, however we believe it would be more consistent to place this example in the NMIG than part of the ESRS ","G1","G1-1 - Policies related to business conduct","AR 2"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","DASB supports the adjustments to increase interoperability with SFDR. Focus on alignment SFDR will we needed in future since SFDR will also be adjusted - how to make sure consistency remains in the future. Suggestion to add an evaluation clause or direct link to SFDR","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","The adjusted sentence is hard to read. Suggestion to use an alternative formulation, for example splitting 10a in two sentences since it contains two requirements","G1","G1-2 - Actions related to business conduct","10. (a)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","The adjusted sentence is an improvement, however we suggest to rephrase the sentence by changing \"any\" into \"the\" in the phrase: \"[..] which includes any actions taken to address breaches in procedures and standards of anti-corruption and anti-bribery.\" ","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","DASB supports the adjustments to increase interoperability with SFDR. Focus on alignment SFDR will we needed in future since SFDR will also be adjusted - how to make sure consistency remains in the future. Suggestion to add an evaluation clause or direct link to SFDR","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","DASB supports the adjustments to increase interoperability with SFDR. Focus on alignment SFDR will we needed in future since SFDR will also be adjusted - how to make sure consistency remains in the future. Suggestion to add an evaluation clause or direct link to SFDR","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","Functions and or roles depends on the way the undertaking defines it. Stimulates entity specific reporting but simultaneously hampers comparability. Furthermore, we question the informative value of the disclosure and see a risk for boiler plate language.","G1","G1-1 - Policies related to business conduct","8. (c)"]
["Excels","Dutch Accounting Standards Board","(National) standard setter","Netherlands",null,null,"I partially agree and partially disagree","The DASB notes that G1.12 under b is an existing requirement inrespect of legal proceedings for late payments, however the DASB expects an SME to experience a high threshold to start such legal proceedings. Additionally, this focus on legal proceedings outstanding, information about legal proceedings in this respect concluded during the year might be a valuable","G1","G1-1 - Policies related to business conduct","12."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Business conduct should not include aspects of animal welfare, especially because there are no other DR's in regards to animal welfare. ","G1","G1-1 - Policies related to business conduct","7."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be stated that it is ok, if processes to respond to allegations or incidents should only be descibed once for all kind of incidents e.g. human rights, discrimination, corruption & bribery. Furthermore metrics for all kind of incidents should also stated only once in a clearly arranged way.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be added, that a reference to the EU transparency register or national transparency register is sufficient to fulfill this DR, if the data is available in the register. (16. & 17.)","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","There is no common definition for main category. Please delete the term main category and add options for the undertaking for differentiation of categories, countries, or other criteria","G1","G1-6 - Metrics in relation to payment practices","20."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The wording of the objective of G1-6 is not reflected in the corresponding requirements.","G1","G1-6 - Metrics in relation to payment practices","19."]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","If these specific categories of delivery files are requested, we cannot provide any information. Our suppliers are not sorted into categories in any way.\n\nIf these specific supplier categories are required, we are unable to provide any information. Our suppliers are not sorted into categories in any way.\n\nFurthermore, we are unable to determine whether a supplier is an SME, as no data is available for this purpose. The question also remains as to which definition of SME should be used here.\n\nThe terms and conditions are very often specified by our suppliers or agreed upon individually, even though a few K+S subsidiaries have their own payment terms. -> In the case of individual agreements, there is therefore an automatic deviation from the standard – what significance does the file then still have?","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","German Chemical Industry Association","Business association (other than association of financial institution)","Germany",null,null,"I disagree","The derivation of the sample is omitted (former ESRS-G1.33d).\n\nAccordingly, we would have to say whether ALL suppliers are complying with the payment terms. However, this is not possible because not all companies are managed in SAP and not all companies have their own defined payment terms – this would require time-consuming manual queries! Determining the key figure thus becomes highly complex and even more time-consuming than before.","G1","G1-6 - Metrics in relation to payment practices"]
["Excels","The Polish Chamber of Information Technology and Telecommunications","Business association (other than association of financial institution)","Poland",null,null,"I disagree","While it is understandable why EFRAG wishes to focus on SMEs, it unfortunately does not match business reality. Companies do not tier their suppliers based on their size. Therefore it is impossible to extract such detailed information without undue cost or effort, such as surveying all suppliers on their size and adding new elements to currently operating supplier management systems. We believe that information on payment practices applied to all suppliers, without prejudice, would be sufficient to meet the goal of fair presentation of weather the issuer follows best practices in that respect. Therefore, keeping the division between all suppliers and SMEs as a requirement goes against the goal of simplification and avoiding undue cost or effort in the process of sustainability reporting.  ","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","We recommend to limit the disclosure for individual case of corruption to the top management and not to all individuals, which could be interpreted in a much broader sense.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is still not clear what is intended for \"comparable position\". The Standard should give clear guidance in order not to over report on comparable positions, as not all the positions held in public administration have the same relevance (e.g. if someone was in the board of statutory auditors of an hospital is not probably a relevant information).\nFurthermore, a clarification of what is included in the definition of \"public administration\" is critical.","G1","G1-5 - Metrics related to political influence and lobbying activities","10."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","It is still very difficult to calculate the percentage of payment practices aligned with the payment standard terms, especially for companies operating in several different countries. We suggest to limit this disclosure to the most relevant countries. ","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Refered to comment onn §2c - these requirements are excessive, it shall be up to undertaker to choose the functions / roles at high risk and do the training accordingly.","G1","G1-2 - Actions related to business conduct","7."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The requirement could ask either the persentage or the number as the exact percentage of employees trained is difficoult to disclose, due to the natural turnover of staff/roles ","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 5"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 6"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The requirements to explain the topics discussed is excessive, a company may have hundred of such meeting per year.","G1","G1-5 - Metrics related to political influence and lobbying activities","9."]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 7"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 8"]
["Excels","IOGP Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Wrong reference","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 9"]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The information required in [DRAFT] ESRS G1-5 on political influence and lobbying activities is redundant with other EU transparency requirements. Companies should be allowed to reference the EU transparency register or any other relevant national registers for the purpose of this disclosure.","G1","G1-5 - Metrics related to political influence and lobbying activities","5."]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","G1 definitions, and specifically the one for \"Corruption and bribery convictions\" are not aligned with United Nations Convention against Corruption or with the OECD, adding new definitions or making references to regional (ECRIS) (instead of global) references. Where available, widely accepted global frameworks should be the basis for definitions (e.g. the UN Convention or OECD). ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","Missing detail on internal viewing policies such as company employment terms and conditions. These are important and fundamental when doing investigations.","G1","G1-1 - Policies related to business conduct","1."]
["Excels","Cefic","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","\"Confirmed incidents\" should refer to proven cases after internal investigation, simple alerts should not be disclosued.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","Only the policies for the complaints procedure are adressed in G1-1. In order to bundle the requirements on the complaints procedure, it would be advisable to bundle this reporting requirement together with the reporting requirements of ESRS S1-2, S2-2, S2-3 and S2-4 on the complaints procedure in a separate chapter. This would support the opportunitie to refer to the descriptions under G1 in the S chapters. ","G1","G1-1 - Policies related to business conduct","8. (b)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","The metrics relating to anti-corruption and anti-bribery are comprehensible and ok. When summarizing the sub-sub-topics in the ESRS 1 standard, anti-corruption and anti-bribery, animal welfare and complaints procedures were combined in one Sub-Topic. It is unclear why the topics of animal welfare and complaints procedures no longer appear separately in standard G1. This is an inconsistency between the topic overview in ESRS 1 and the G1 standard that should be rectified (see also comment on ESRS G1 - 8)","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA. The requirement to report on \"standard payment terms\" and supplier categorization presents significant practical challenges. The metric lacks clarity in international contexts and provides limited value for understanding supplier relationships. Tracking supplier categories by size would require substantial system changes, while reporting legal proceedings related to late payments without context offers little decision-useful information, especially since material cases are already covered in legal risk reporting. These requirements create unnecessary administrative burden without adding meaningful value to sustainability reporting.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA.","G1","G1-5 - Metrics related to political influence and lobbying activities","15."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I partially agree and partially disagree","It should be made clearer that only those metrics are to be reported for sub-topics that have been assessed as essential in the context of the DMA.","G1","G1-6 - Metrics in relation to payment practices","19."]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","It is unclear to which paragraphs the AR refers to (also AR 4-6). Paragraphs 13/14 do no longer exist in the amended ESRS. Update of references/paragraphs needed.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Considering the EFRAG Explanations January - May 2024 (final version,page 95), the following issues are identified:\n1.\t It focuses solely on first-instance convictions of natural persons, including non-final decisions, leading to a lack of transparency and contradictions with the ECRIS, which only records final convictions.\n2.\tThe CSRD approach lacks transparency by mixing final and non-final convictions. A final conviction has more significance than a non-final decision.\n3.\tTh approach fails to distinguish between the severity of convictions of board members versus employees, and it does not consider cases where the company itself is sanctioned for corruption or bribery, either through criminal proceedings or administrative fines. Relevant national registers for legal entities are disregarded by the CSRD as well. Cases where a company is sanctioned for corruption or bribery are important, as they indicate systemic issues rather than individual excesses.\n4.\tAdditionally, the reliance on information from accused individuals creates reliability issues, as court proceedings often occur years after the offense, and the employees may no longer be with the company. \n5.\tThe focus on payable fines for convictions of natural persons overlooks prison sentences (and their suspension if applicable), which are indicators of the severity of the crime.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","5. (a)"]
["Excels","ZVEI e.V.","Business association (other than association of financial institution)","Germany",null,null,"I disagree","Suggestion to delete this datapoint as information already disclosed in EU Transparency Register as well as in national Transparency Registers (e.g. Germany, USA) and therefore considered redundant. Additionally, a prioritization of “main topics in lobbying activities” could imply that political activities in one country could be more important or “material” than in another leading to misunderstandings with external stakeholders.","G1","G1-5 - Metrics related to political influence and lobbying activities","9."]
["Excels","SAIM GmbH","Consultant (including software vendor)","Germany",null,null,"I partially agree and partially disagree","Unclear what is meant by standard payment terms (and that it isn't the average time to pay). Why was the example taken out from the application requirements? That was helpful","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I partially agree and partially disagree","In addition to the elements listed under ESRS 2 GDR-P, business conduct policies should disclose topic-specific features—for instance, whether whistleblower systems accept reports from external stakeholders, how whistleblowers are protected, and whether policy effectiveness is regularly assessed. These dimensions are critical for understanding governance in practice and avoiding reporting gaps.","G1","G1-1 - Policies related to business conduct","10."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I agree","It is positive that key policy areas such as anti-corruption and whistleblower protection are explicitly singled out for disclosure. This supports consistency with EU regulatory frameworks (e.g. SFDR) and addresses areas of high stakeholder concern. No changes needed. ","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","BDO Poland","Auditor","Poland",null,null,"I partially agree and partially disagree","The requirement lacks clarity on the scope of “business conduct policies”. Without further guidance, undertakings may omit key policies due to unawareness or intentional exclusion. Including a non-exhaustive list of typical business conduct policy areas would support more complete and comparable disclosures.","G1","G1-1 - Policies related to business conduct","7."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I agree","Including a dedicated disclosure requirement for targets within ESRS G1 is strongly supported. This ensures alignment with the overall ESRS architecture and improves consistency between G, E, and S topics. No changes needed. ","G1","G1-3 - Targets related to business conduct","11."]
["Excels","BDO Poland","Auditor","Poland",null,null,"I partially agree and partially disagree","The current drafting allows undertakings to declare zero political contributions without substantiating how this conclusion was reached. Requiring a short description of the methodology in case of no identified contributions (e.g. data sources, internal controls, scope of review) would enhance reliability. This ensures disclosures reflect actual due diligence and minimize underreporting.","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I partially agree and partially disagree","Lots of DP merge into this paragraph. Ok for the DP but the presentatin is not so clear. Better to put differetn bullet points with the DP.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","LABORATOIRES PIERRE FABRE","Preparer (non-financial preparing a sustainability report)","France",null,null,"I agree","Number of confirmed incidents of corruption mandatory","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","European Association of Co-operative Banks (EACB)","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","The consolidation of subtopics is not always effective. Excessive aggregation may dilute relevant aspects. For instance, for credit institutions it seems reasonable to address the topic of “corruption and bribery” separately, rather than combining it with less related issues such as whistleblowing or animal welfare. The draft foresees a consolidation of sub- and sub-sub-topics at the sub-topic level, with sub-sub-topics being removed. This has implications for the materiality assessment, particularly in relation to governance. The topic ‘corruption and bribery’ is now subsumed under ‘corporate culture’, together with whistleblower protection and animal welfare. As a result, the term ‘corporate culture’ is given a deviating definition, and the topic of ‘corruption and bribery’—which is often assessed as material and clearly defined—loses significance. A clearer definition of ‘corporate culture’ as well as a separate consideration of ‘corruption and bribery’ as its own sub-topic would appear appropriate to ensure a clear delineation of topics for the materiality assessment. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden",null,null,"I agree","(Former G1-1 Disclosure Requirement related to ESRS 2 GOV-1 – The role of \nthe administrative, management and supervisory bodies) - It is good that it is handled in ESRS 2 GOV1 instead of seperated reporting in each topical standard. ","G1","G1-1 - Policies related to business conduct","6."]
["Excels","Kjell & Company","Preparer (non-financial preparing a sustainability report)","Sweden",null,null,"I partially agree and partially disagree","Great modification to only disclose discrepencies, but which specific chapter and/or articles in UN Convention against Corruption are applicable to a company? Please specify. Otherwise it is hard to compare against. Is it Article 12? ","G1","G1-1 - Policies related to business conduct","8."]
["Excels","ASSIREVI","Auditor","Italy",null,null,"I partially agree and partially disagree","We propose to restore the existing para. 33(a) related to the average time to pay an invoice because this data is used to respond to subsequent requests (see current para. 20(a)). We therefore believe that it would not be an excessive effort for users to report it.","G1","G1-6 - Metrics in relation to payment practices","20."]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","This adds an additional disclosure requirements for preparers. We believe that the principle of not increasing reporting requirements should be applied consistently. Even if the datapoint itselbf is not technically complex, the change in status to mandatory will require additional interpretation, internal coordination, and alignment with auditors—especially during first-time implementation. This effort should not be underestimated. From our point of view the ESRS revision should refrain from posing any additional effort to preparers.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Mercedes-Benz Group AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","This application requirements is not clearly defined and prone to diverse interpretation, e.g.:\n- \"shall consider\": does this mean that incidents in the upstream/downstream value chain are to be disclosed?\n- what is meant by \"direct involvement\"?\n- does the reporting include information about the \"actors\"?","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The objective described in para. 1 of each draft topical ESRS is inconsistent with Draft ESRS 1. The statement about “dependencies when relevant” and “financial effects” should be deleted to make it consistent with ESRS 1.\n\nChange the wording to:\n\n\"When reporting in accordance with the ESRS, the sustainability statement shall cover information in relation to [Draft] Amended ESRS G1 Business Conduct when this topic relates to material impacts, risks and opportunities. The disclosure on the material impacts, risks and opportunities is expected to cover policies, actions, metrics and targets (if in place).\"","G1","G1 - Objective","1."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Why is (unfair) put in brackets? Depending on what the intention was, either delete the brackets or delete the (unfair) in its entirety.","G1","G1 - Objective","4. (b)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Remove parts (a) and (b) and keep the introductory paragraph to avoid unnecessary dupplication. Paragraph 5 should read as follows:\n\n\"The undertaking shall apply the provisions of [Draft] Amended ESRS 2 paragraphs 29 to 32 and GDR-P, GDR-A, GDR-T and GDR-M.\"","G1","G1 - Objective","5."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","Why is this paragraph needed? Is this not sufficiently covered in ESRS 2, Paragraph 30?\n\nSince former S1- to S4 requirements were moved into the new ESRS 2, Paragraph 35 the question arises if for ESRS G1, Paragraph the same logic should apply.\n\nEither way, the approach should be consistent across ESRS.","G1","G1-1 - Policies related to business conduct","8."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Starting with DR G1-2, the numbering of paragraphs starts with 1 again instead of continuing the paragraph count of the paragraph. This paragraph should read as 9 and then the numbering should be continued. ","G1","G1-2 - Actions related to business conduct","9."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Part 1 of feedback on G1-2, paragraph 10(c):\n\nThe whole approach to supply chain management requires reconsideration. On the one hand, supply chain components are inherent in each of the E, S and G standards, whereas ESRS G1 seems to suggest that this is a component of G. It could also be argued that it is most appropriate to reflect supply chain management in the section on general information because the supply chain is often managed across E, S and G in which case it would be most appropriate to reflect this in the general information section. If fair presentation should be the overarching principle, it should be considered if the last sentence in Paragraph 10(c) actually should belong here. We also believe that changing this from voluntary to mandatory represents an arbitrary extension of reporting and is not sufficiently justified. \n\n[Feedback on this paragraph is continued below. The below entry should be read after this entry.]\n\n","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Part 2 of feedback on G1-2, paragraph 10(c):\n\nIf left unamended, we would appreciate more guidance on when the disclosure of 'whether the procurement team is involved in training related to its engagement with suppliers for the improvement of their sustainability performance' within paragraph 10(c) is required, whether it is required when the sub-topic \"Management of relationships with suppliers\" is deemed material and/or the other sub-topics under G1 are deemed material. In the NMIG's \"Mapping of sub-topics to disclosures in topical standards\", G1-2 has been mapped to all three sub-topics under G1, however it does not seem all datapoints within G1-2 are related to all the sub-topics under G1.\n\nIn general, despite the non-mandatory status, some guidance provided in the NMIG may cause more confusion than clarify for preparers. In view of the above example, we would appreciate the provision of more clarifications on the use of the mapping provided in NMIG, and more broadly on circumstances where preparers have challenges applying the guidance in the NMIG.   ","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Why is the addition during the reporting period needed? Is it not clear from ESRS 2 that all disclosures made refer to the reporting period? Please check all ESRS in this respect.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Why is the addition during the reporting period needed? Is it not clear from ESRS 2 that all disclosures made refer to the reporting period? Please check all ESRS in this respect.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","13."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","It is still not clear whether the number of convictions for violation of anti-corruption and anti- bribery laws applies only to the legal entity , or whether it should also include employees and members of the 'administrative, management and supervisory bodies' (AMSB) of the entity. It should be clarified that this applies to legal entities and not individual persons.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","13."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","In relation to the new G1-6 paragraph 13, we suggest to split the two requirements (i.e. number of convictions and total amount of fines) into different paragraphs for better clarity, given that the scopes of such metrics are indeed different.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","13."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Why is the addition during the reporting period needed? Is it not clear from ESRS 2 that all disclosures made refer to the reporting period? Please check all ESRS in this respect. See also our response to question 23.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","Response to Part 2 Q23 (1):\n\nAFME strongly opposes this additional mandatory datapoint. There is not sufficient justification for adding this quantitative disclosure requirement as it does not align with the simplification principles set out by the Commission for the revision of ESRS. Members have previously raised concerns about the application of definition of “confirmed” incidents and the challenges with applying the Glossary definitions on a global scale, where ESRS definitions may deviate from individual jurisdictional definitions. The new ARs 4-6 do not provide the flexibility required for reporters operating globally. Preparers should not be mandated to disclose information which poses a legal risk to the institution – this should align with reliefs available in the context of financial reporting. \n\n[the response is continued in another field]","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","Response to Part 2 Q23 (2):\n\nThe proposed mandatory disclosure of the number and nature of “confirmed” incidents of corruption and bribery would potentially impair an undertaking and its parent company’s legal strategy/defence and risk mitigation. Determinations as to whether or not a legal violation has occurred, and the appropriate enforcement response, are generally discretionary decisions by competent authorities. The proposed disclosure may be interpreted by authorities in and outside Europe as an admission of violation by the undertaking or its parent company, regardless of specific facts and circumstances (e.g., materiality and nature of identified misconduct). This may bias an investigation and enforcement response. Such information is also highly sensitive and complex to report in a public document. Broad sharing of sensitive information could be detrimental for various reasons (e.g. potential breach of confidentiality obligations as regards certain transactions). It is to be stressed though that, for the sake of transparency, the corresponding information is already shared with a restricted list of stakeholders (Board of Directors, auditors and certain supervisory authorities).\n\nConsequently, the disclosure requirement can result in undue harm and legal risk to the undertaking and its parent company. Internal investigations by the undertaking, even if substantiated, should not be reportable.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","It should be clarified that this refers only to employees who are active in the reporting period.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","AR 4 aligns its interpretation of \"final decision\" with the concept of a \"conviction\" under the European Criminal Courts Records Informatin System (ECRIS). In Regulation EU 2019/816 (ECRIS-TCN), the concept of a conviction is defined as a definitive resolution where no appeal is possible. The log of amendments (referring to AR 4) states the following: \"In this context, final decisions include all the decisions in the reporting year while awaiting the outcome of a possible appeal. The reporting undertaking may provide additional information if an appeal is considered, has been lodged or was successful\". The log of amendments, therefore, introduces a discrepency.\n\nIt is essential that, to avoid any misinterpretation, the concept of conviction in AR 4 for paragraph 13 refers to final decisions not subject to appeals, and therefore paragraph added in the Log of Amendments is deleted and not added to any subseqent Q&A as it is incorrect pursuant to Regulation ECRIS.\n\n","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","The application requirements should specify that reporting on G1-4 should focus on convictions to legal entities, not to individual persons.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I partially agree and partially disagree","Regarding AR 5 for p. 13, in order to keep coherence with the definition of \"conviction\" under the European Crimal Courts Records Infomation System, fines to be reported should be those that are definitive (i.e. not subject to appeal judicially). This would be also consistent with the concept of \"fair presentation\" pursued by the new ESRS.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 5"]
["Excels","The Association for Financial Markets in Europe","Association of financial institutions","United Kingdom",null,null,"I disagree","The requirements of G1-5 should be clarified to affirm that the disclosure is associated with the EU and its member states in recognition of the fact that not all jurisdictions have regulatory structures akin to the EU Transparency Register and substantial investment would be required for firms to collect, track and report information from third parties. They also go beyond current EU Transparency Register requirements. In particular, we thought the prior paragraph 29(b)(i) should have been modified to drop the reference to “indirectly” which arguably could be seen to cover payments to trade organizations that may engage with political officials either through conferences/lunches or through direct contributions. Such activity may have little connection to material ESG issues (e.g. meeting to discuss rules for participating in local check clearing market), and the EU would still have the benefit of the EU registrations and disclosures for EU-related activity under the existing EU Transparency Register. The exposure draft does not clarify this, and we ask that this is considered further. ","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","It is unclear to which paragraphs the AR refers to (also AR 4-6). Paragraphs 13/14 do no longer exist in the amended ESRS. Update of references/paragraphs needed.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Considering the EFRAG Explanations January - May 2024 (final version,page 95), the following issues are identified:\n1.\t It focuses solely on first-instance convictions of natural persons, including non-final decisions, leading to a lack of transparency and contradictions with the ECRIS, which only records final convictions.\n2.\tThe CSRD approach lacks transparency by mixing final and non-final convictions. A final conviction has more significance than a non-final decision.\n3.\tTh approach fails to distinguish between the severity of convictions of board members versus employees, and it does not consider cases where the company itself is sanctioned for corruption or bribery, either through criminal proceedings or administrative fines. Relevant national registers for legal entities are disregarded by the CSRD as well. Cases where a company is sanctioned for corruption or bribery are important, as they indicate systemic issues rather than individual excesses.\n4.\tAdditionally, the reliance on information from accused individuals creates reliability issues, as court proceedings often occur years after the offense, and the employees may no longer be with the company. \n5.\tThe focus on payable fines for convictions of natural persons overlooks prison sentences (and their suspension if applicable), which are indicators of the severity of the crime.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","5. (a)"]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","By deleting \"for financai or in kind political contributions\", the requirements seem to suggest that the total monetary calue of financial and in-kind political contributions for \"political influence\" needs to be disclosed. This in turn would increase the reporting burden for companies as it widens the defition of the metrics to be reported to general political influence , while at the same time being open for interpretation. Generally, the collection of information for this datapoint requires a lot of effort and raises legal concerns especially related to in-direct financial contributions outside of the EU, which is why we would suggest to limit the scope from \"global! to \"EU and Member States\" or delete the datapoint. Alternatively, further clarification on the scope needed.","G1","G1-5 - Metrics related to political influence and lobbying activities","8."]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","Suggestion to delete this datapoint as information already disclosed in EU Transparency Register as well as in national Transparency Registers (e.g. Germany, USA) and therefore considered redundant. Additionally, a prioritization of “main topics in lobbying activities” could imply that political activities in one country could be more important or “material” than in another leading to misunderstandings with external stakeholders.","G1","G1-5 - Metrics related to political influence and lobbying activities","9."]
["Excels","Siemens AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The requirement to report on \"standard payment terms\" and supplier categorization presents significant practical challenges. The metric lacks clarity in international contexts and provides limited value for understanding supplier relationships. Tracking supplier categories by size would require substantial system changes, while reporting legal proceedings related to late payments without context offers little decision-useful information, especially since material cases are already covered in legal risk reporting. These requirements create unnecessary administrative burden without adding meaningful value to sustainability reporting.","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","Leaseurope","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","The requirements of G1-5 should be clarified to affirm that the disclosure is associated with the EU and its member states in recognition of the fact that not all jurisdictions have regulatory structures akin to the EU Transparency Register and substantial investment would be required for firms to collect, track and report information from third parties that may be required given broad definitions.  They also go beyond current EU Transparency Register requirements. In particular, we thought the prior paragraph 29(b)(i) should have been modified to drop the reference to “indirectly” which arguably could be seen to cover payments to trade organizations that may engage with political officials either through conferences/lunches or through direct contributions.  Such activity may have little connection to material ESG issues (e.g. meeting to discuss rules for participating in local check clearing market), and the EU would still have the benefit of the EU registrations and disclosures for EU-related activity under the existing EU Transparency Register. The exposure draft does not clarify this, and we ask that this is considered further. ","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Leaseurope","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Since, as noted in G1-4, this disclosure requirement has been included to support the information needs of financial market participants subject to Regulation (EU) 2019/2088, it is not directly applicable in the context of private companies, and therefore should be excluded or at least caveated to exclude private companies.   [Please note we wished to select 'I partially agree and partially disagree' in our response, but were unable to do so]","G1","G1-4 - Metrics related to Incidents of corruption or bribery","13."]
["Excels","Leaseurope","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Reporting of this information is already required in (most) EU constituencies, and this datapoint includes requirements that are not only redundant, but that also exceed the scope of existing EU legislation, introducing new obligations not required under the Transparency Register framework. [Please note we wished to select 'I partially agree and partially disagree' in our response, but were unable to do so]","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Leaseurope","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","For privately and in particularly family-held company this could include sensitive information. While the ESRS has stated that the purpose of these included data points is to enhance transparency for investors and stakeholders, it is reasonable that the ESRS should take into account the specific perspective and context that private companies operate in to make appropriate rules for reporting that that may be distinct from those applicable to publicly listed companies. This is another one of those cases, as this data point requires the reporting of  business sensitive information held by a privately-held company that is generally otherwise not subject to public disclosure. Further, this requirement improperly limits flexibility. The IFRS allows for principles-based disclosures, while ESRS imposes structured datapoints, which may not suit all governance models (especially US-based or family-owned firms). Instead, companies should be able to screen applicable categories for materiality and to limit disclosures to material items. [Please note we wished to select 'I partially agree and partially disagree' in our response, but were unable to do so]","G1","G1-5 - Metrics related to political influence and lobbying activities","18."]
["Excels","ETSA ","Business association (other than association of financial institution)","Belgium",null,null,"I partially agree and partially disagree","If companies are required to disclose specific payment amounts to individual associations, there is a risk that conclusions relevant to competition could be drawn from this. There are very different models for calculating membership fees in the association landscape, for example based on total payroll or company turnover. Disclosing specific contribution amounts to individual organisations could enable competitors who are members of the same association to derive sensitive information about other companies. We therefore propose that only the type of recipient should be disclosed, but not specific organisations or contribution amounts.","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Eurometaux (European Metals Association)","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","In the mining industry, supplier-related data is mostly uncategorized in the way requested. Suppliers are mainly managed individually, and payment conditions are negotiated on a case-by-case basis. Applying this categorisation will increase complexity in reporting","G1","G1-6 - Metrics in relation to payment practices","20."]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Strong opposition is expressed to converting G1-4 25(a) from a voluntary to a mandatory datapoint under G1-14. EFRAG’s rationale, an exception justified by the absence of other metrics on corruption and bribery, is insufficient and inconsistent with its mandate to simplify and reduce reporting burdens.\n\nThis change represents a significant shift in scope and expectations. EFRAG has not provided a compelling reason, and elevating this datapoint without compelling justification undermines the credibility of the standard-setting process and imposes undue burden. The EU Commission’s clear instruction to EFRAG, repeatedly emphasized, is that voluntary datapoints should not become mandatory without overwhelming justification. The claim that “no other metrics exist” does not meet that threshold.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","MedTech Europe","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Strong opposition is expressed to the conversion of G1-2 AR (b) from a voluntary to a new mandatory datapoint under G1-4 10(c). \n\nEFRAG’s rationale, that this change replaces two deleted datapoints on supplier relationship management and was deemed “more meaningful”, is insufficient and inconsistent with its stated mandate to simplify and reduce reporting burdens.\n\nThis change introduces a significant shift in scope without compelling justification. EFRAG has consistently stated that voluntary datapoints should only be made mandatory under exceptional circumstances. The assertion of increased relevance is subjective and does not sufficiently account for the diversity of supplier governance models or the potential for immaterial disclosures.\n\nEFRAG must adhere to its principles of proportionality and materiality. Elevating this datapoint to mandatory status without overwhelming justification undermines the credibility of the standard-setting process. We urge EFRAG to retain the datapoint as voluntary.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","10. (c)"]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I agree","Paragraph 9 sets the objective of G1-2 very clearly.","G1","G1-2 - Actions related to business conduct","9."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","This amendment meets the purpose of having the information requirement set out. However, we suggest adapting the text to emphasise alignment with applicable legislation, rather, without obliging companies to disclose potentially sensitive information. for example, the clause can be formulated as follows: 10. In addition to the information required by ESRS 2 GDR-1, the undertaking shall disclose: a) information about the management of its relationships with its suppliers,  if the undertaking takes into account social and environmental criteria for the selection of its suppliers based on the applicable legal requirements.","G1","G1-2 - Actions related to business conduct","10. (a)"]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I agree","These paragraphs were unnecessarily complicating the disclosures. Nokia welcomes the simplification.","G1","G1-2 - Actions related to business conduct","13."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","The meaning of \"confirmed incident\" should be revised as indicated in a prior comment. Additionally, we do not support the addition of this new mandatory disclosure requirement and respectfully request that it be adapted as follows: \"The undertaking may disclose the total number and nature of confirmed incidents of corruption or bribery that occurred during the reporting period\".  ","G1","G1-2 - Actions related to business conduct","14."]
["Excels","Nokia","Preparer (non-financial preparing a sustainability report)","Finland",null,null,"I partially agree and partially disagree","While the distinction between DPs political influence and lobbying activities is welcome, the definition of what exactly constitutes \"political influence\" needs to be added to the glossary of terms, especially given the distinction between \"financial and in-kind political contributions\".  ","G1","G1-2 - Actions related to business conduct","16."]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","We recommend that EFRAG provide a definition of unfair payment practices, this concept being newly introduced in the ED.","G1","G1 - Objective","4. (c)"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","We recommend that EFRAG clarify the scope of people directly involved in incidents of corruption or bribery to be considered as AR 3 refers to 'employees' while NMIG 4 refers to 'own workers' (i.e., including non-employees). ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","The new definition of fines provided in AR 5 limits the information to be disclosed to the fines 'paid to a public treasury'. We recommend that EFRAG clarifies whether fines that comply with the applicable definition but which are paid to other bodies shall be considered  in reporting under ESRS G1:13.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Deloitte","Auditor","Spain",null,null,"I partially agree and partially disagree","We recommend that EFRAG clarify whether investigations of government authorities on the undertaking’s payment practices are to be considered as 'legal proceedings currently outstanding for late payments'. Clarifications brought by ID 419 could be usefully added to specify what 'currently outstanding legal proceedings'  refer to (i.e. 'legal proceedings that have not been legally resolved at year-end') and whether proceedings initiated and closed during the reporting period shall also be considered.","G1","G1-6 - Metrics in relation to payment practices","20."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","EDITORIAL \n\"(unfair) payment practices\" - not clear whether this is asking undertakings to report on unfair payment practices or both, fair and unfair practices; log of amendment states that the amendment by \"(unfair)\" was intended to align with CSRD, but CSRD (recital (50)) does not use brackets and is therefore clear in the sense that it refers to \"unfair payment practices\" only; par 4(b) should be aligned (i.e. remove brackets)","G1","G1 - Objective","4. (b)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","On paras 8(a) and 8(b) \n\"the circumstances when it has no policies on …\" The change in the wording does not add to the clarification. The earlier version: \"When it has no policies… it shall state and whether it has plans to implement\" is perceived as clearer. The wording in ESRS G1 amend raises the question as to whether there is an expectation of a different disclosure now. The intention is that undertakings disclose when they do not have that policiy. However, now it could be read as if the circumstances of that are asked to be disclosed. Suggestion: keep current wording.","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I agree","generally agree that streamlining two DP into one new DR; here: 10(c) includes new DR, but that DR (procurement team involved in training) included to replace / streamline two other data points  on management of relationship with suppliers","G1","G1-1 - Policies related to business conduct","10. (c)"]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I agree","from may to shall (exception) as there would be no other remaining metrics on corruption and bribery ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","4."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I partially agree and partially disagree","On para 7 et seq. \nAccording to the log of amendments the changes in G1 amend par. 7 et seq are meant to clearer distinguish between political influence and lobbying activities by differentiating between the two. However, this seems difficult to establish in G1-5. For example, par 7 states that the objective is - among other - to provide \"types ... of lobbying activities\" when in fact par 8 asks of different types of \"political influence\". Lobbying activities (par 9) are not differentiated by type, but by main topics etc. Therefore, it does not seem to clarify any differences between the two (especially since lobbying activities are (correctly) still explained as being included in \"political influence\" activities (par 7). ","G1","G1-5 - Metrics related to political influence and lobbying activities","7."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","Question 32) in the questionnaire, the log of amendments to G1 and BC (p. 66) refer to simplifications in G1-6. However, the amended requirements regarding \"payment practices\" are still questionable. While the objective of G1-6 is theoretically understandable (to have visibility regarding how undertakings engage with and support SMEs - Questionnaire, p. 23) this objective does not seem achievabel in practice. \n\nThe objective of G1-6 states that the disclosure is to provide an understanding of the contractual payment terms ... especially with regard to late payments to SMEs. However, this objective cannot be met with the disclosure requirements in the paragraph that follows. On a minor note, par 12 does not provide for a disclosure regarding \"late payments to SMEs\" so this information cannot be derived from par. 12. In addition, par 12 remains unclear about how the disclosures are supposed to provide information on the payment practices in relation to SMEs; e.g. (a) requires information on payment terms / percentage aligned with these terms \"including SMEs\" - would this require a disclosure separately for SMEs or one total disclosure including the number of days for SMEs? \n[continues in box below]\n","G1","G1-6 - Metrics in relation to payment practices","11."]
["Excels","DRSC","(National) standard setter","Germany",null,null,"I disagree","[continued from box above] \nApart from the wording of the DR which does not reflect the objective of G1-6 we got the feedback that there are several issues with this DR: First of all, there often is no \"standard payment term\" per category of suppliers. More importantly, \"SMEs\" do not represent one \"category of suppliers\". To separate  SMEs from other suppliers would often not be possible for undertakings as they do not usually categorise their suppliers by size and therefore usually do not have the information on which supplier is an SMEs (also questionable which definition to apply here). \nAs mentioned above, companies have reported back that they do not have \"standard payment terms\", but that the terms are very different across suppliers (also depending on the request of suppliers as payment terms are often prescribed by the supplier). As a result, there is no \"standard payment terms\" in regards to SMEs that could be reported. \n\nOverall, while G1 par 33(a) (current ESRS Set 1) has been deleted the general issue regarding \"payment practices\" in general and with regard to SMEs in particular remain. ","G1","G1-6 - Metrics in relation to payment practices","11."]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","While consolidating previous scattered datapoints on training into a single provision is understandable, the proposed approach introduces ambiguities. The current wording largely retains original phrasing, resulting in multiple distinctive datapoints in section 10c: general business conduct training (formerly 10g); percentage of high-risk functions/roles trained on corruption and bribery (formerly 21b); board members trained (formerly 21b); and members of the “procurement team” trained. Except for general training, it is unclear whether data should cover these groups regarding business conduct or anti-corruption specifically.\n\nMoreover, if these requirements are combined into one larger datapoint, undertakings that previously deemed DR G1-2 on supplier relationships non-material may be unsure whether reporting becomes mandatory under the proposed ED. The term “procurement team” also lacks clarity.\n\nWe recommend designing training datapoints with clear requirements and ensuring disclosure scope aligns with materiality principles, particularly regarding supplier relationships. Additionally, the percentage of high-risk functions/roles trained provides limited value, as definitions vary across companies, reducing comparability. The first part of §10(c) already offers a sufficient overview of relevant training measures.","G1","G1-2 - Actions related to business conduct","10 c)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","ESRS G1 §18  It is unclear what “lobbying activities” refers to, considering that there is no harmonized regulation across Europe that defines it.\nTherefore, we suggest amending the definition in the glossary as such:\nActivities carried out with the objective of influencing the formulation or implementation of policy or legislation, or the decision-making processes of governments, governmental institutions, regulators, European Union institutions, bodies, offices and agencies or standard setters. Such activities include (non-exhaustive list):\ni.\torganising or participating in meetings, conferences, events; \nii.\tcontributing to/participating in public consultations, hearings or other similar initiatives;\niii.\torganising communication campaigns, platforms, networks, grassroots initiatives;\niv.\tpreparing/commissioning policy and position papers, opinion polls, surveys, open letters, research work as per the activities covered by transparency register rules.\nActivities carried out by, among others, business associations in the exercise of their constitutional functions shall not be considered lobbying activities","G1","G1-5 - Metrics related to political influence and lobbying activities","17"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","It is unclear what “regulators” refers to. Therefore, we would suggest a modification: “The disclosure shall also include information about the appointment of any members of the administrative, management and supervisory bodies who held a comparable political position in public administration (including regulators) in the 2 years preceding such appointment in the current reporting period.”","G1","G1-5 - Metrics related to political influence and lobbying activities","18"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","While consolidating previous training datapoints into a single provision is understandable, the proposed approach creates new ambiguities. The wording largely preserves original phrasing, resulting in multiple distinctive datapoints in section 10c: general business conduct training (formerly 10g); percentage of high-risk functions/roles trained on corruption and bribery (formerly 21b); board members trained (formerly 21b); and members of the “procurement team” trained. Except for general training, it is unclear whether data should cover these groups regarding business conduct or anti-corruption specifically.\n\nIf these requirements are treated as a single, larger datapoint, undertakings that previously deemed DR G1-2 on supplier relationships non-material may be uncertain whether reporting becomes mandatory under the proposed ED. The term “procurement team” is also unclear.\n\nWe recommend designing training datapoints with clear requirements and ensuring disclosure scope aligns with materiality principles, especially regarding supplier relationships. The datapoint on the percentage of high-risk functions/roles trained adds limited value, as definitions vary across companies, reducing comparability. The first part of §10(c) already provides an adequate overview of relevant training measures.","G1","G1-2 - Actions related to business conduct","10 c)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","ESRS G1 §18  It is unclear what “lobbying activities” refers to, considering that there is no harmonized regulation across Europe that defines it.\nTherefore, we suggest amending the definition in the glossary as such:\nActivities carried out with the objective of influencing the formulation or implementation of policy or legislation, or the decision-making processes of governments, governmental institutions, regulators, European Union institutions, bodies, offices and agencies or standard setters. Such activities include (non-exhaustive list):\ni.\torganising or participating in meetings, conferences, events; \nii.\tcontributing to/participating in public consultations, hearings or other similar initiatives;\niii.\torganising communication campaigns, platforms, networks, grassroots initiatives;\niv.\tpreparing/commissioning policy and position papers, opinion polls, surveys, open letters, research work as per the activities covered by transparency register rules.\nActivities carried out by, among others, business associations in the exercise of their constitutional functions shall not be considered lobbying activities","G1","G1-5 - Metrics related to political influence and lobbying activities","17"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","It is unclear what “regulators” refers to. Therefore, we would suggest a modification: “The disclosure shall also include information about the appointment of any members of the administrative, management and supervisory bodies who held a comparable political position in public administration (including regulators) in the 2 years preceding such appointment in the current reporting period.”","G1","G1-5 - Metrics related to political influence and lobbying activities","18"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","While consolidating scattered training datapoints into a single provision is understandable, the proposed approach introduces new ambiguities. The wording largely retains the original phrasing, resulting in multiple distinctive datapoints in section 10c: general business conduct training (formerly 10g); percentage of high-risk functions/roles trained on corruption and bribery (formerly 21b); board members trained (formerly 21b); and members of the “procurement team” trained. Except for general training, it is unclear whether data should cover these groups regarding business conduct or anti-corruption specifically.\n\nIf these requirements are combined into one larger datapoint, undertakings that previously assessed DR G1-2 on supplier relationships as non-material may be uncertain whether reporting becomes mandatory under the proposed ED. The term “procurement team” also lacks clarity.\n\nWe recommend designing training datapoints with clear requirements and ensuring that disclosure scope aligns with materiality principles, particularly regarding supplier relationships. The datapoint on the percentage of high-risk functions/roles trained adds limited value, as definitions vary across companies, reducing comparability. The first part of §10(c) already provides an adequate overview of relevant training measures.","G1","G1-2 - Actions related to business conduct","10 c)"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","ESRS G1 §18  It is unclear what “lobbying activities” refers to, considering that there is no harmonized regulation across Europe that defines it.\nTherefore, we suggest amending the definition in the glossary as such:\nActivities carried out with the objective of influencing the formulation or implementation of policy or legislation, or the decision-making processes of governments, governmental institutions, regulators, European Union institutions, bodies, offices and agencies or standard setters. Such activities include (non-exhaustive list):\ni.\torganising or participating in meetings, conferences, events; \nii.\tcontributing to/participating in public consultations, hearings or other similar initiatives;\niii.\torganising communication campaigns, platforms, networks, grassroots initiatives;\niv.\tpreparing/commissioning policy and position papers, opinion polls, surveys, open letters, research work as per the activities covered by transparency register rules.\nActivities carried out by, among others, business associations in the exercise of their constitutional functions shall not be considered lobbying activities","G1","G1-5 - Metrics related to political influence and lobbying activities","17"]
["Excels","Insurance Europe and Insurance CFO Forum","Association of financial institutions","Belgium",null,null,"I partially agree and partially disagree","It is unclear what “regulators” refers to. Therefore, we would suggest a modification: “The disclosure shall also include information about the appointment of any members of the administrative, management and supervisory bodies who held a comparable political position in public administration (including regulators) in the 2 years preceding such appointment in the current reporting period.”","G1","G1-5 - Metrics related to political influence and lobbying activities","18"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The input refers to G1-2 Paragraph 2 (c): \n\nConsolidation of different training purposes and activities could be challenging with view to the IRO mapping process, as it fails to clearly indicate which sub-topic G1-2 Paragraph 2 (c) relates to. Therefore, a more distinct division into the sub-topics is necessary. Especially, the disclosure requirement regarding the procurement team should be separated as it refers to the topic management of relationships with suppliers.\n\nThe new wording regarding the members of the administrative, management and supervisory bodies is not clear. Recommendation: Revert to the previous text and include 'the extent to which training is given to'. Alternatively, it should be emphasized that external training is also meant in order to prevent potential conflicts of interest.\n","G1","G1-2 - Actions related to business conduct","7."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The input refers to G1-3 Paragraph 6:\n\nA disclosure requirement regarding the number and nature of confirmed incidents of corruption and bribery is misleading and should be deleted. A high number of incidents seems negative but might also reflect an effective compliance management system with investigation measures in place. \nIn addition, the disclosure requirement contradicts 1. the principle of the presumption of innocence and 2. the principle under German law that offenses do not regularly have to be reported to the authorities, but it is the company's responsibility to adequately address compliance violations within the company.\n\nThere is no unified scope or definition of the term „corruption incidents“, neither in the affected jurisdictions and their criminal codes, nor within the undertakings reporting this KPI. For example: does corruption only mean corruption in the public or also in the private sector? Are cases of conflicts of interests covered? Are only incidents covered with confirmed violations of criminal law or also of a violation against internal rules only? What does “confirmed” mean: indictment by a prosecutor; internally proven; internal assessment that violation is highly probable or only more likely than not? These different assessment methods will lead to confusing reported data. ","G1","G1-3 - Targets related to business conduct","7."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The input refers to G1-5, AR 7 and 8 for para 16:\n\nRegarding political contributions further differentiation and explanation is needed (the purpose of a contribution as main criteria): \nFinancial or in-kind contributions to external organizations (e.g. lobbyists, charities, think tanks or trade associations) or non-consolidated companies should only be considered, if granted with the purpose of passing it on to a relevant recipient like political parties, their elected representatives or persons seeking political office.\n","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 7"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","This application requirements is not clearly defined and prone to diverse interpretation, e.g.:\n- \"shall consider\": does this mean that incidents in the upstream/downstream value chain are to be disclosed?\n- what is meant by \"direct involvement\"?\n- does the reporting include information about the \"actors\"?","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","This adds an additional disclosure requirements for preparers. We believe that the principle of not increasing reporting requirements should be applied consistently. Even if the datapoint itselbf is not technically complex, the change in status to mandatory will require additional interpretation, internal coordination, and alignment with auditors—especially during first-time implementation. This effort should not be underestimated. From our point of view the ESRS revision should refrain from posing any additional effort to preparers.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","ACEA","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","It is recommended to have a disclosure focus on robust risk mitigation policies, processes, and identification of at-risk roles, not percentages. While clarifying low-risk roles, this overlooks the dynamic nature of global corporations, making a precise percentage of at-risk functions unfeasible. ","G1","G1-3 - Targets related to business conduct","10."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","Overall, the structure of G1 chapter is now consistent with other topical chapters, by introducing ‘PAT’ (Policies, Actions, Targets). This is helpful and adds to the logic order, also of sustainability statements.","G1","",""]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","We welcome the inclusion of examples for 'functions and/or roles most at risk'.","G1","G1-2 - Actions related to business conduct","AR 2"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","This paragraph introduces a mandatory disclosure 'whether the procurement team is involved in training related to its engagement with suppliers for the improvement of their sustainability performance'. The datapoint is combining very different areas, under Business Conduct header. While understanding these points all relate to training, it is not a helpful structure to combine unrelated areas and have different datapoints 'hidden' in one DR.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","The paragraph mentions 'the undertaking shall disclose (..) training activities (..). This shall include the percentage of functions and/or roles most at risk within the undertaking in respect of corruption and bribery (..)' The disclosure requirement is unclear, what is meant with 'the percentage'? Does it refer to the percentage of functions or roles, out of the total of functions or roles within the company, that are at risk? Or the percentage training completion by this group, which is not what it says?","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","We welcome the inclusion of guidance for 'Convictions', adding to consistency in reporting. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","We welcome the inclusion of guidance for 'Fines', adding to consistency in reporting. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 5"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","We welcome the explicit reference to the ESRS definition of 'Corruption' and 'Bribery', adding to consistency in reporting.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 6"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","This datapoint has been made mandatory under the ESRS revisions, which is contrary to the general principle of simplifying the ESRSs.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","AR 7 and AR 8 include definitions for the terms used in paragraph 16. This is an example of where definitions are included in the AR, while other definitions (in this case, lobbying activities) are covered in Annex II. This inconsistency is confusing when applying. ","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 9"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Please see response in PART 2 template","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I agree","Comment applies to the overall objective of G1 - article 3. It explicitely states that  the undertaking only to disclose on the subtopics that are material - like in all other ESRSs except S1. This should be applied to S1 as well.","G1","G1-1 - Policies related to business conduct","7."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Remove reference to payment practices which is not a sustainability topic and does not add decision useful information for readers of the Sustainability Statement","G1","G1 - Objective","4. (b)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","The PAT structure does not make sense for some of the G1 - Business Conduct topics, which should be included by all companies as mandatory e.g. Codes of Conduct / Supplier Conduct. Further this now creates significant diversion from other regulation where companies are required to provide more extensive disclosures on business conduct, policies, speak up processes, how business conduct matters are investigated therefore synergies between the Sustainability Statement and other sections of the Annual Report have been lost. Removal of requirements around Speak Up / non retaliation also lead to additional effort being required in Social Dislosures to report on channels / remedy which were cross referenced to G1 by many companies. In addition, it is unclear why reporters have been asked to continue to include information if ABC or whistleblowing policies not in place but no longer a mandate to explicitly say these policies are in place through GDRs.","G1","G1-1 - Policies related to business conduct","7."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","This requirement should be made 'where relevant' as many companies will have a company wide approach to corruption and bribery.","G1","G1-1 - Policies related to business conduct","8. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","The PAT structure does not make sense for some of the G1 - Business Conduct topics, which should be included by all companies as mandatory. Actions in relation to business conduct etc are likely to be BAU and part of policies therefore unlikely to be able to meet GDRs, however will still be recognised as material as it only takes one issue to potentially become material from a reputational perspective. Ok for other topics such as Animal Welfare.","G1","G1-2 - Actions related to business conduct","9."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Aligned to retain this requirement but similar requirements need to be kept in policies section to allow for a coherent narrative. Fundamentally EFRAG need to rethink G1 structure and whether some elements need to be retained in addition to PAT GDRs","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Depth of coverage' needs to be removed or better defined. Requirements relating to functions / roles most at risk should be made 'where relevant' as many companies will have a company wide approach to corruption and bribery .","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I partially agree and partially disagree","Disagree with making requirements relating to procurement team involvement in training mandatory. The more relevant data points are to understand how policies are embedded into the value chain and how this is monitored. Also not considering that other teams may be involved in training.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","The PAT structure does not make sense for some of the G1 - Business Conduct topics, which should be included by all companies as mandatory. In addition, businesses are unlikely to have public targets in these areas nd will be promoting a zero tolerance policy therefore do not feel this is relevant.","G1","G1-3 - Targets related to business conduct","11."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Metrics related to payment practices should be removed as it is not a sustainability topic and does not add decision useful information for readers of the Sustainability Statement. Significant issues would either be reported through the financial statements or other external sources. ","G1","G1-6 - Metrics in relation to payment practices","19."]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Definition amended with the deletion of \"An incident of corruption or bribery that has been found to be substantiated\". This should stay in as such incidents can only be reported once substantiated and confirmed. If not retain, this creates inconsistencies in definition and use of the word \"incident\" between S and G topical standards and metrics (see further comments in S1)","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 6"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","Regarding paragraph 10(c) 'percentage of functions at risk', we noticed a change from 'percentage of functions at risk covered by training'; the log of amendments clarifies that not all roles within a function may be at risk. While we support reporting the percentage of at-risk functions and administrative, management and supervisory board members covered by training, identifying specific roles within those functions and determining the % of functions at risk in an organization as a datapoint separate from training coverage reduces comparability due to differing role structures and risk assessments, and increases reporting burden without a clear benefit.\n\nNoting from the NMIG, this is not the intention of this paragraph, however may be interpreted this way given the current phrasing.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","The Financial Executives Association (FEA)","Other - please specify (required)","Netherlands",null,null,"I disagree","We note that examples have been added to AR 2 for paragraph 8(c), clarifying that functions or roles most at risk may include those operating in high-risk countries or interacting with public authorities. While we understand the intent, this addition introduces ambiguity and could lead to unintended consequences, such as EU companies being perceived as singling out foreign governments. In practice, such interactions are already captured through disclosing the functions at risk (e.g. procurement). Under the fair presentation framework introduced in the revised ESRS 1, companies may feel compelled to disclose on these examples where material, which could increase the risk of double counting and create unnecessary complexity including around (legal) sensitivities. We therefore recommend retaining the original phrasing.\n\nWe propose that this paragraph be repositioned as non-mandatory implementation guidance, rather than an application requirement. This would preserve the original intent of encouraging transparency without imposing prescriptive disclosure expectations that may not be relevant or material for all entities.","G1","G1-2 - Actions related to business conduct","AR 2"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","Clarify in the guidance how UN Convention against Corruption interacts with national laws, such as Sapin II in France","G1","G1-1 - Policies related to business conduct","8. (a)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Delete datapoint on confirmed incidents. Mandatory reporting would pose risks to European companies’ competitiveness. It could conflict with the right against self-incrimination guaranteed by the European Convention on Human Rights and expose EU companies to investigations by third-country authorities, such as the US Department of Justice, benefiting non-EU competitors not subject to similar obligations. In the joint statement on a US-EU framework for reciprocal, fair, and balanced trade, the EU is called upon to ensure that the CSRD and CSDDD do not impose undue restrictions on transatlantic trade. Introducing mandatory reporting of confirmed incidents risks creating an unlevel playing field, as US companies may be exempted from comparable constraints.\nMoreover, reporting confirmed incidents is not a reliable indicator of anti-corruption policy effectiveness. A low number of incidents could reflect strong preventive measures, while a high number may indicate a trusted reporting system, particularly through whistleblowing channels. A simple numerical count or brief description of an incident’s “nature” cannot capture its context, resolution, or remedial actions. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Delete the data point on the appointment of governance body members who held a comparable position in public administration within the past two years, as it is less relevant than disclosure on financial and in-kind political contributions, and poses implementation challenges","G1","G1-5 - Metrics related to political influence and lobbying activities","18."]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","Maintain a requirement on the management of relationships with suppliers, as these data points are seen as crucial by users to approximate key exposures, assess supplier concentration risks, monitor supply chain resilience, and inform risk management practices\n\nProposed wording:\n“The undertaking shall provide information about the management of its relationships with \nits suppliers and its impacts on its supply chain, including:\na) a general description of tier 1 suppliers, including, where possible without undue cost or effort, the estimated number of tier 1 suppliers, and, on a voluntary basis, the estimated number of strategic suppliers among them; and\nb) the percentage of tier 1 suppliers audited and/or evaluated in number and by purchasing amount.”","G1","G1-2 - Actions related to business conduct","10. (a)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I partially agree and partially disagree","ANC suggests retaining datapoints on the management of relationships with suppliers (previously addressed under G1-2 and now deleted) as a higher priority compared to the datapoint on the training of procurement teams. These datapoints are particularly important for users to approximate key exposures, assess supplier concentration risks, monitor supply chain resilience, and inform risk management practices.\nSuggested wording:\n“The undertaking shall provide information about the management of its relationships with \nits suppliers and its impacts on its supply chain, including:\na) a general description of tier 1 suppliers, including, where possible without undue cost or effort, the estimated number of tier 1 suppliers, and, on a voluntary basis, the estimated number of strategic suppliers among them; and\nb) the percentage of tier 1 suppliers audited and/or evaluated in number and by purchasing amount.”\nIf training for procurement teams is maintained as a datapoint without more information required on policies and actions related to the management of supplier relationships, it may be more appropriate to place it under (d) rather than (c), in order to clearly distinguish supplier relationship management from topics related to functions exposed to corruption risk.","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Autorité des normes comptables (ANC)","(National) standard setter","France",null,null,"I disagree","ANC strongly rejects changing datapoints on confirmed incidents from “may” to “shall,” as they are highly sensitive and of limited relevance.\nMandatory reporting would pose risks to European companies’ competitiveness. It could conflict with the right against self-incrimination guaranteed by the European Convention on Human Rights and expose EU companies to investigations by third-country authorities, such as the US Department of Justice, benefiting non-EU competitors not subject to similar obligations. In the joint statement on a US-EU framework for reciprocal, fair, and balanced trade, the EU is called upon to ensure that the CSRD and CSDDD do not impose undue restrictions on transatlantic trade. Introducing mandatory reporting of confirmed incidents risks creating an unlevel playing field, as US companies may be exempted from comparable constraints.\nMoreover, reporting confirmed incidents is not a reliable metric of anti-corruption policy effectiveness. A low number of incidents could reflect strong preventive measures, while a high number may indicate a trusted reporting system, particularly through whistleblowing channels. A simple numerical count or brief description of an incident’s “nature” cannot capture its context, resolution, or remedial actions.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","\"Political influence\" appears in bold in ED G1 § 4 c) however this concept is not defined in the ED Glossary. We recommend EFRAG provides a definition of this concept.\nThe segregation between \"political influence\" and \"lobbying activities\" in the list of ESRS G1 sub-topics (§ 4) intends to show that they are different concepts. However, the objective of DR G1-5 of the ED suggests that \"lobbying activities\" are included in \"political influence\" (“provide an understanding of the undertaking’s activities and commitments related to exerting its political influence with political contributions, including the types and purpose of lobbying activities”). This aligns with Q&A EFRAG ID 510 which defines lobbying activities as \"influencing politics, political decisions, laws and regulations\".  \nWe recommend that EFRAG provides a definition of \"political influence\", clarifying whether \"political influence\" covers both \"political contribution\" and \"lobbying activities\" and whether payments made for lobbying activities are included in political contributions.","G1","G1 - Objective","4. (c)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","Amended list of ESRS G1 sub-topics now includes \"(unfair) payment practices\". We recommend that EFRAG provides a definition for \"unfair\" payment practices.","G1","G1 - Objective","4. (b)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","ESRS G1 § 10 a) requires disclosing \"information about the management of relationships with suppliers\".  As this datapoint is a datapoint of the \"DR G1-2 – Actions related to business conduct\", we recommend EFRAG clarifies whether the \"information\" relates specifically to “actions” or intend to cover other concepts to be disclosed such as governance structures (oversight of supplier relationships), strategic approach and policies (driving the actions). \nWe also recommend EFRAG sharing in NMIG examples of types of actions which could be disclosed in respect of \"management of relationships with suppliers\" based on already observed practices. Those examples could include :  setting an organization dedicated to purchases and supplier relationships with management involvement, or  alignment of policies in place within the undertaking and policies included in contractual clauses signed with suppliers to show consistency of policies application all along the undertaking value chain, with references to the parts of the sustainability statements already describing those policies.\n","G1","G1-2 - Actions related to business conduct","10. (a)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","The definition of “incidents” has been revised in the glossary and now includes : “These include judicial and non-judicial proceedings that have been initiated”. We recommend EFRAG to add a definition for “proceedings” as well as examples of “non-judicial proceedings”.","G1","G1-2 - Actions related to business conduct","10. (b)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","ESRS G1 § 10 c) requires to disclose \"depth of coverage\" of \"training activities within the undertaking on business conduct\". \"Depth of coverage\" is not defined by the standard or glossary. \nG1-2 NMIG 3 for para. 10(c) presents an illustrative table including a \"Training coverage\" section referring to the percentage of trained people and a \"Topics covered\" section. \nWe recommend the AR to clarify  whether “depth of coverage” refers to percentage of trained people AND topics covered during the reporting period or whether “depth of coverage” shall be defined by the undertaking and could refer for example to the level of training (e.g. basic, advanced or expert)\n","G1","G1-2 - Actions related to business conduct","10. (c)"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","Corruption definition included in the ESRS Glossary is very large and we recommend further clarifications by providing :\n- a definition of “entrusted power”\n- illustration of incidents that correspond to incidents of corruption or bribery and clarify whether the two following situations are in scope of ESRS G1-4 DR:\n                              - accounting manipulation\n                              - environmental pollution incident with corruption of agent involved in the investigation.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","12."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","We recommend that EFRAG clarify which population is in scope for each datapoint related to G1-4 DR, as there are contradicting elements in the related AR and in NMIG : AR 3 for para 13 and 14 refers to incidents \"where the undertaking or its employees are directly involved\".  AR 4 for para 13 refers to \"an individual\". Lastly, NMIG 4 4 for para. 14 refers to \"own workers\".\nOwn workers include employees and non-employees. An individual can be an employee, a non-employee, a worker in  the value chain, a member of administrative, management and supervisory board who is an individual within the undertaking organization but not an employee.\n","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","In the document \"Log of amendments ESRS G1 Business Conduct July 2025\", AR 4 paragraph for para 13 includes the following wording : “In this context, final decisions include all the decisions in the reporting year while awaiting the outcome of a possible appeal. The reporting undertaking may provide additional information if an appeal is considered, has been lodged or was successful.” This wording is not included in AR4 of the ESRS G1 standard ED. We recommend that EFRAG adds this wording in ESRS G1 - AR 4 of the standard considering this clarification is key to determine G1-4 metrics in case of a situation where an appeal is pending.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 4"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","We acknowledge EFRAG’s effort to clarify convictions and fines. We note that EFRAG has specified the scope of fines to those \"paid to a public treasury\" : it should be clarified if it was the intent to deliberately limit the scope, i.e.  the public treasury must be the direct recipient of the payment. This could exclude relevant information as in some countries local fines may be paid to other bodies (independent public authorities which are not the public treasury), or proceedings could lead to payment to third parties or foreign authorities. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 5"]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","Scope of ESRS G1 § 14 covers incidents \"that occurred during the reporting period\". G1-4 NMIG 4  for para. 14 suggests including in corruption and bribery cases  the \"cases that were initiated in previous years where the outcome was only established in the current reporting period.\" We recommend that EFRAG transfers this NMIG 4 into an AR related to DR G1-4 as this clarification is key to ensure the information is comparable across undertakings (material incidents which were substantiated during the reporting period but occurred before the reporting period should be covered by the sustainability statement). ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I partially agree and partially disagree","G1-5 NMIG 5 for para. 17 suggests to check the alignment between an undertaking’s public statements on its material IRO  and its lobbying activities. This was previously included in ESRS G1 AR 14 (Set 1). We recommend EFRAG retains this aspect into an AR related to G1-5 § 17 as it is necessary to ensure consistency and transparency on whether the lobbying activities are supportive, contradictory or neutral to the company’s sustainability commitments.\nWe also recommend that EFRAG adds into NMIG examples of ways to conduct lobbying activities based on 2024 observed disclosures such as implementation of a Public Affairs department or registration in transparency register.","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Ernst & Young","Auditor","United Kingdom",null,null,"I agree","We recommend that EFRAG defines “SME” or clarify that it should align with the criteria set in the accounting directive.\n\nG1-6 § 20 a) requires description of payment terms by main category of suppliers, including SMEs. \nIt is unclear whether SME information is required irrespective of the materiality of this supplier category from the perspective of the undertaking. This is considering the CSRD objective (protection of SMEs), the DR objective (understanding payment terms “especially with regard to late payments to SMEs”) and the requirement itself. \nTransactions with SMEs may not be material from the perspective of the undertaking.  \nIf the intention is to address specific users’ needs, we recommend to clearly state it in a standalone requirement for SME specific payment practice – distinct from other suppliers. \n\nWe recommend EFRAG clarifies in AR whether the percentage of payment aligned with standard terms shall be computed based on:\n-  the number or the amount of invoices, \n-  the payments including or excluding reverse factoring transactions,\n-  the population of all payments made during the reporting period including invoices received or dated in a different reporting period.\n\nWe also recommend adding in NMIG 6 illustrative figures in the “Standard payment terms (days)” column.","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The input refers to G1-2 Paragraph 2 (c): \n\nConsolidation of different training purposes and activities could be challenging with view to the IRO mapping process, as it fails to clearly indicate which sub-topic G1-2 Paragraph 2 (c) relates to. Therefore, a more distinct division into the sub-topics is necessary. Especially, the disclosure requirement regarding the procurement team should be separated as it refers to the topic management of relationships with suppliers.\n\nThe new wording regarding the members of the administrative, management and supervisory bodies is not clear. Recommendation: Revert to the previous text and include 'the extent to which training is given to'. Alternatively, it should be emphasized that external training is also meant in order to prevent potential conflicts of interest.\n","G1","G1-2 - Actions related to business conduct","7."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The input refers to G1-3 Paragraph 6:\n\nA disclosure requirement regarding the number and nature of confirmed incidents of corruption and bribery is misleading and should be deleted. A high number of incidents seems negative but might also reflect an effective compliance management system with investigation measures in place. \nIn addition, the disclosure requirement contradicts 1. the principle of the presumption of innocence and 2. the principle under German law that offenses do not regularly have to be reported to the authorities, but it is the company's responsibility to adequately address compliance violations within the company.\n\nThere is no unified scope or definition of the term „corruption incidents“, neither in the affected jurisdictions and their criminal codes, nor within the undertakings reporting this KPI. For example: does corruption only mean corruption in the public or also in the private sector? Are cases of conflicts of interests covered? Are only incidents covered with confirmed violations of criminal law or also of a violation against internal rules only? What does “confirmed” mean: indictment by a prosecutor; internally proven; internal assessment that violation is highly probable or only more likely than not? These different assessment methods will lead to confusing reported data. ","G1","G1-3 - Targets related to business conduct","7."]
["Excels","BMW AG","Preparer (non-financial preparing a sustainability report)","Germany",null,null,"I disagree","The input refers to G1-5, AR 7 and 8 for para 16:\n\nRegarding political contributions further differentiation and explanation is needed (the purpose of a contribution as main criteria): \nFinancial or in-kind contributions to external organizations (e.g. lobbyists, charities, think tanks or trade associations) or non-consolidated companies should only be considered, if granted with the purpose of passing it on to a relevant recipient like political parties, their elected representatives or persons seeking political office.\n","G1","G1-5 - Metrics related to political influence and lobbying activities","AR 7"]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The requirements of G1-5 should be clarified to affirm that the disclosure is associated with the EU and its member states in recognition of the fact that not all jurisdictions have regulatory structures akin to the EU Transparency Register and substantial investment would be required for firms to collect, track and report information from third parties that may be required given broad definitions.  They also go beyond current EU Transparency Register requirements. In particular, we thought the prior paragraph 29(b)(i) should have been modified to drop the reference to “indirectly” which arguably could be seen to cover payments to trade organizations that may engage with political officials either through conferences/lunches or through direct contributions.  Such activity may have little connection to material ESG issues (e.g. meeting to discuss rules for participating in local check clearing market), and the EU would still have the benefit of the EU registrations and disclosures for EU-related activity under the existing EU Transparency Register. The exposure draft does not clarify this, and we ask that this is considered further. ","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Since, as noted in G1-4, this disclosure requirement has been included to support the information needs of financial market participants subject to Regulation (EU) 2019/2088, it is not directly applicable in the context of private companies, and therefore should be excluded or at least caveated to exclude private companies.  ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","13."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","It is recommended to maintain as a voluntary disclosure to avoid unintended legal and agency implications. Requiring legal violation disclosure imposes a new, potentially serious obligation in Europe where no affirmative duty currently exists. ","G1","G1-4 - Metrics related to Incidents of corruption or bribery","14."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Reporting of this information is already required in (most) EU constituencies, and this datapoint includes requirements that are not only redundant, but that also exceed the scope of existing EU legislation, introducing new obligations not required under the Transparency Register framework.","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","For privately and in particularly family-held company this could include sensitive information and even information relating to minors in certain circumstances. While the ESRS has stated that the purpose of these included data points is to enhance transparency for investors and stakeholders, it is reasonable that the ESRS should take into account the specific perspective and context that private companies operate in to make appropriate rules for reporting that that may be distinct from those applicable to publicly listed companies. This is another one of those cases, as this data point requires the reporting of  business sensitive information held by a privately-held company that is generally otherwise not subject to public disclosure. Further, this requirement improperly limits flexibility. The IFRS allows for principles-based disclosures, while ESRS imposes structured datapoints, which may not suit all governance models (especially US-based or family-owned firms). Instead, companies should be able to screen applicable categories for materiality and to limit disclosures to material items.","G1","G1-5 - Metrics related to political influence and lobbying activities","18."]
["Excels","American Chamber of Commerce to the EU","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","It is recommended to have a disclosure focus on robust risk mitigation policies, processes, and identification of at-risk roles, not percentages. While clarifying low-risk roles, this overlooks the dynamic nature of global corporations, making a precise percentage of at-risk functions unfeasible. ","G1","G1-3 - Targets related to business conduct","10. (c)"]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","If these specific categories of delivery files are requested, we cannot provide any information. Mining suppliers are not sorted into categories in any way.\nIf these specific supplier categories are required,it is not possible to provide any information - and often it is not feasible to determine whether a supplier is an SME, as no data is available for this purpose.\nThe terms and conditions are very often specified by our suppliers or agreed upon individually -> In the case of individual agreements, there is therefore an automatic deviation from the standard.","G1","G1-6 - Metrics in relation to payment practices","20."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The wording of the objective of G1-6 is not reflected in the corresponding requirements.","G1","G1-6 - Metrics in relation to payment practices","19."]
["Excels","Euromines","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Accordingly, we would have to say whether ALL suppliers are complying with the payment terms. However, this is not possible because not all companies are managed in SAP and not all companies have their own defined payment terms – this would require time-consuming manual queries","G1","G1-6 - Metrics in relation to payment practices","20. (a)"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","It is unclear to which paragraphs the AR refers to (also AR 4-6). Paragraphs 13/14 do no longer exist in the amended ESRS. Update of references/paragraphs needed.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","AR 3"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Considering the EFRAG Explanations January - May 2024 (final version,page 95), the following issues are identified:\n1.\t It focuses solely on first-instance convictions of natural persons, including non-final decisions, leading to a lack of transparency and contradictions with the ECRIS, which only records final convictions.\n2.\tThe CSRD approach lacks transparency by mixing final and non-final convictions. A final conviction has more significance than a non-final decision.\n3.\tTh approach fails to distinguish between the severity of convictions of board members versus employees, and it does not consider cases where the company itself is sanctioned for corruption or bribery, either through criminal proceedings or administrative fines. Relevant national registers for legal entities are disregarded by the CSRD as well. Cases where a company is sanctioned for corruption or bribery are important, as they indicate systemic issues rather than individual excesses.\n4.\tAdditionally, the reliance on information from accused individuals creates reliability issues, as court proceedings often occur years after the offense, and the employees may no longer be with the company. \n5.\tThe focus on payable fines for convictions of natural persons overlooks prison sentences (and their suspension if applicable), which are indicators of the severity of the crime.","G1","G1-4 - Metrics related to Incidents of corruption or bribery","5. (a)"]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","By deleting \"for financai or in kind political contributions\", the requirements seem to suggest that the total monetary calue of financial and in-kind political contributions for \"political influence\" needs to be disclosed. This in turn would increase the reporting burden for companies as it widens the defition of the metrics to be reported to general political influence , while at the same time being open for interpretation. Generally, the collection of information for this datapoint requires a lot of effort and raises legal concerns especially related to in-direct financial contributions outside of the EU, which is why we would suggest to limit the scope from \"global! to \"EU and Member States\" or delete the datapoint. Alternatively, further clarification on the scope needed.","G1","G1-5 - Metrics related to political influence and lobbying activities","8."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","Suggestion to delete this datapoint as information already disclosed in EU Transparency Register as well as in national Transparency Registers (e.g. Germany, USA) and therefore considered redundant. Additionally, a prioritization of “main topics in lobbying activities” could imply that political activities in one country could be more important or “material” than in another leading to misunderstandings with external stakeholders.","G1","G1-5 - Metrics related to political influence and lobbying activities","9."]
["Excels","DIGITALEUROPE","Business association (other than association of financial institution)","Belgium",null,null,"I disagree","The requirement to report on \"standard payment terms\" and supplier categorization presents significant practical challenges. The metric lacks clarity in international contexts and provides limited value for understanding supplier relationships. Tracking supplier categories by size would require substantial system changes, while reporting legal proceedings related to late payments without context offers little decision-useful information, especially since material cases are already covered in legal risk reporting. These requirements create unnecessary administrative burden without adding meaningful value to sustainability reporting.","G1","G1-6 - Metrics in relation to payment practices","12."]
["Excels","Polish Chamber of Chemical Industry","Business association (other than association of financial institution)","Poland",null,null,"I partially agree and partially disagree","The concept of a “function exposed to corruption” is not defined. In practice, companies often state that they do not identify such functions, leading to a lack of disclosures. More detailed guidance is needed to ensure meaningful and comparable reporting.","G1","G1 - Interaction with other ESRS","1."]
["Excels","UNESPA (Spanish Association of Insurers and Reinsurers)","Association of financial institutions","Spain",null,null,"I disagree","It is necessary to clarify that business associations, when exercising their constitutional functions, shall not be regarded as engaging in lobbying activities. Therefore, in the interest of legal certainty, we would suggest incorporating the following final sentence at the end of the definition of lobbying activities, specifically in the 'Glossary' section: \n\n\"Activities carried out with the objective of influencing the formulation or implementation of policy or legislation, or the decision-making processes of governments, governmental institutions, regulators, European Union institutions, bodies, offices and agencies or standard\nsetters. Such activities include (non-exhaustive list):\ni. organising or participating in meetings, conferences, events;\nii. contributing to/participating in public consultations, hearings or other similar\ninitiatives;\niii. organising communication campaigns, platforms, networks, grassroots initiatives;\niv. preparing/commissioning policy and position papers, opinion polls, surveys, open\nletters, research work as per the activities covered by transparency register rules.\n\nActivities carried out by, among others, business associations in the exercise of their constitutional functions shall not be considered lobbying activities.\"       ","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","UNESPA (Spanish Association of Insurers and Reinsurers)","Association of financial institutions","Spain",null,null,"I disagree","It is also recommended that the Spanish translation of 'lobbying activities', currently rendered as 'grupos de presión', be changed to 'grupos de interés', in accordance with recent national regulatory developments                                                                                                                 ","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Reclaim Finance","NGO","France",null,null,"I disagree","Paragraph 17 states that: \"The undertaking shall briefly disclose, for lobbying activities, the main topics covered by these activities and its main positions on these, including explanations on how this interacts with its material impacts, risks and opportunities identified in its materiality assessment (See [Draft] Amended ESRS 2 IRO-2).\" While this is fully relevant, it is stricking to see that no direct link is made between the lobbying activities and the climate transition plan in E1-1. Disclosures on assumptions regarding the transition plans are also required, and yet entities would not provide information on how this is reflected in their own advocacy and lobbying activities. For consistency, we therefore recommend the Efrag to require entities to report on how their lobbying activities are compatible and contribute to the achievement of their climate transition plan (in G1-5 or in E1-1).","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Reclaim Finance","NGO","France",null,null,"I partially agree and partially disagree","The monetary amounts devoted to political activities beyond \"political contributions\" (for example through spending on a public policy department, hiring private lobbyists, organizing events..) should also be disclosed.","G1","G1-5 - Metrics related to political influence and lobbying activities","16."]
["Excels","Reclaim Finance","NGO","France",null,null,"I disagree","The current wording do not cover the lobbying activities carried out through representative organizations. Yet we know that the bulk of lobbying activities go through these bodies and can have large consequences on policies. We would therefore recommend the mandatory disclosure of elements on how the activities of these organization is coherent with the ones of the entity and its own targets and plans. ","G1","G1-5 - Metrics related to political influence and lobbying activities","17."]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The objective of sustainability reporting prepared in accordance with the ESRS is to present fairly (see Chapter 2) the undertaking’s material impacts on people and environment, as well as the material sustainability risks and opportunities (collectively referred to as ‘impacts, risks and opportunities’) in relation to environmental, social and governance topics. Reporting under these two perspectives constitutes the double materiality principle. An ESRS sustainability statement covers governance, strategy, policies, actions, targets and metrics for topics related to material impacts, risks and opportunities. PROPOSED: The objective of sustainability reporting prepared in accordance with the ESRS is to assist informative decision making by external and internal stakeholders of the reporting entity through establishing structural approach to fairly disclose information related to undertakings impacts, risks and opportunities on people and environment. An ESRS sustainability statement covers governance, strategy, policies, actions, targets and metrics for topics related to material impacts, risks and opportunities.","ESRS1","","3"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The undertaking shall update the conclusions of the materiality assessments conducted in the previous reporting periods to take into account changed circumstances and/or assumptions. Because of changes in its individual circumstances or in the external environment, some types of information included in its ESRS sustainability statement for prior periods might no longer be material; conversely, some types of information not previously disclosed might become material. PROPOSED: The undertaking shall review its DMA on annual basis and adjust it if needed by considering significant/critical changes in the internal and external environment. Following this regular monitoring the information presented in a Sustainability statement from previous period may be no longer material and/or new material information may be disclosed. ","ESRS1","","29"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The impact materiality assessment corresponds to the identification of information that relates to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short, medium or long term. Impacts include those connected with its own operations, products, or services, including through business relationships in its upstream and downstream value chain. Business relationships are not limited to direct contractual relationships. PROPOSED: The impact materiality assessment includes established processes for identification, analyses, assessment and monitoring of undertakings social and environmental impacts covering its own operations and its value chain. Undertaking`s risk management system shall be able to identify and assess such impacts as they may be linked to significant operational, strategic, compliance and financial risks and/or opportunities.  For the purpose of sustainability reporting the impacts are grouped in potential/actual negative and potential/actual positive. ","ESRS1","","30"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: …………… If the undertaking has taken remediation actions during the reporting period to address actual negative impacts, these actions shall not be considered when assessing the materiality of the impact. Where the impact is deemed material based on this assessment, the undertaking shall disclose the remediation actions undertaken and their expected or actual outcomes. PROPOSED: Actions taken during the reporting year to remediate material impact shall be reported, including their expected or actual outcomes.","ESRS1","","34"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: For actual negative impacts, materiality shall be based on the severity of the impact. For potential negative impacts, it shall be based on a combination of the severity and likelihood of the impact. Severity shall be based on the following factors: the scale, scope and irremediable character of the impact. In the case of a potential negative human rights impact, the severity of the impact takes precedence over its likelihood. PROPOSED: The assessment of impacts considers several factors as follows: a)       for actual negative impact – scale and irremediable character of the impact (severity); b)      for potential negative impact – severity and likelihood;  c)       for actual positive impact – scale;  d)      for potential positive impact – scale and likelihood. ","ESRS1","","31"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The following are two examples of impacts that are connected with the undertaking:  …………. PROPOSED: The following are two examples of impacts that relate to the undertakings value chain: ….","ESRS1","","AR 6"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The severity is assessed based on a combination of its factors, i.e. scale, scope and irremediable character. The undertaking shall also take into account the practical considerations mentioned in AR 18(b): (a)scale: how serious the negative impact is or how beneficial the positive impact is for people or the environment; (b) scope: how widespread the negative or positive impacts are. In the case of environmental impacts, the scope may be understood as the extent of environmental damage or a geographical perimeter. In the case of impacts on people, the scope may be understood as the number of people adversely affected; and c) irremediable character: whether and to what extent the negative impacts could be remediated, i.e. restoring the environment or affected people to their prior state. The severity is assessed based on a combination of its factors, i.e. scale and irremediable character. The undertaking shall also take into account the practical considerations mentioned in AR 18(b):  (a) scale: Answers one or more of the following questions: how serious the negative impact is; how beneficial the positive impact is for people or the environment; how widespread the negative or positive impacts are. In the case of environmental impacts, the scale may be understood as the extent of environmental damage or a geographical perimeter. In the case of impacts on people, the scope may be understood as the number of people adversely affected; and (b) irremediable character: Answers the following questions: whether and to what extent the negative impacts could be remediated, i.e. restoring the environment or affected people to their prior state. ","ESRS1","","AR 7"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: (53) In such situations, the undertaking (Chapter 9.2 applies): (a) discloses under the other topic the negative material impacts or material risks together with the actions that cause them, with a cross-reference to the related topic; and (b) provides a description of how the material negative impacts or material risks are addressed under the topic to which they relate. PROPOSED: Not clear. This should be subject to undertaking`s own preferences under which topic to present the relevant information as long as there is a proper references. ","ESRS1","","44"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The information reported about policies, actions, and targets shall include upstream and/or downstream value chain information only when (and to the extent that) those policies, actions and targets address material impacts, risks and opportunities in the value chain. With reference to metrics, in many cases, in particular for environmental topics for which proxies are available, the undertaking may be able to comply with the reporting requirements by using an estimate without collecting data from the actors in its upstream and downstream value chain, especially from SMEs, such as, for instance, when calculating its greenhouse gas (‘GHG’) Scope 3 emissions (see Chapters 7.2, 7.3 and 7.4). PROPOSED: The reported Policies, actions and targets shall include upstream and/or downstream value chain information only when (and to the extent that) the value chain is within their scope. ","ESRS1","","67"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"General comments: \nActual negative impacts table\n1)\tthe title of column 1 to be “Material impacts”\n2)\tthe question “How to assess” from column 2 and 3 to be deleted as the information provided do not answer the question","ESRS1","","APPENDIX C"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"Potential impacts table: \n1)\tthe title of column 1 to be changed to “ Material potential impacts where:”\n2)\tthe question “How to assess” from column 2 and 3 to be deleted as the information provided do not answer the question\n3)\tC1,R1 to add at the end: in the reporting year; \n4)\tPlease clarify the text in C1,R2 and R4 as currently it is not clear what is the difference between those two cases; \n5)\tIn my opinion the material potential impacts should be reported in all casas no matter whether it is remediated or not, otherwise the readers of the report will be not able to follow up the status of the impacts reported during the years. \nIn addition, in most of the  cases companies have significant inherent risks (such as potential incidents/accidents) that may lead to material impacts (such as dead, other serious injuries, environmental contamination and etc.). Usually such risks have a permanent character and cannot disappear for the next reporting periods. The undertakings should be able to report what kind of internal controls (policies, procedures, instructions and other actions) are in place in order to manage those significant inherent risks and respectively their potential impacts.  ","ESRS1","","APPENDIX C"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: The undertaking shall state that the general requirements of ESRS 1 have been applied for the preparation of its sustainability statement with an indication either (i) that none of the provisions listed in ESRS 2 paragraph 5 apply, or (ii) of which of the provisions listed in ESRS 2 paragraph 5 have been applied, leading to the disclosure of information required in the relevant paragraphs of ESRS 1:  PROPOSED: …. In ESRS 2 paragraph 4","ESRS2","","5"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"ACTUAL: When reporting on policies, actions and targets, the undertaking shall report relevant information, avoiding information that is boilerplate, and therefore not relevant for users for example when policies and actions have been implemented to comply with law and  regulation, or when the necessary information is already provided in accordance with [Draft] Amended ESRS 2 SBM-1. PROPOSED: …….. have been implemented to comply solely with low and regulations…..” Pls. take into account that companies have many HSE policies and actions relevant to this reporting but in the mean time required by low. ","ESRS2","","AR 28"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"PROPOSED: Do not agree that the information is not important compared to other DR. The existence of integrated RM system is crucial for stakeholders to understand whether IRO`s are managed in a systematic, smart and regular basis or on ad hoc/accidental manner. Also, this provides additional information regarding the maturity of the management to govern in efficient and effective way by focusing on significant risks, impacts and opportunities. ","ESRS2","","26 (e) (f)"]
["Excels","Ascendia EOOD","Consultant (including software vendor)","Bulgaria",null,null,null,"RELATED TO GDR-T: Still not clear whether the DR are aiming to present targets related to the strategic sustainability goals of the company or to its material risks, impacts and opportunities. The DRs are mixing both type of targets.  ","ESRS2","","GDR-T"]
["Excels","The Financial Executives Association (FEA)","Business association (other than association of financial institution)","Netherlands",null,null,null,"Typo: It states \"...uses cobalt in its products, which is minded by using children labour...\". I think it would either be \"by using children\" or \"using child labour\"","ESRS1","3.3.1 Impact materiality assessment","AR 6 for para 30."]
["Excels","The Financial Executives Association (FEA)","Business association (other than association of financial institution)","Netherlands",null,null,null,"Typo: Type in sentence, it states \"dt'","ESRS1","7.8 Classified and sensitive information, and information on intellectual property, know-how or results of innovation","101"]
["Excels","The Financial Executives Association (FEA)","Business association (other than association of financial institution)","Netherlands",null,null,null,"Typo: Typo under a, where it should be \"percent\" instead of \"per cent\"","ESRS2","SBM-1 - Strategy, business model and value chain","AR 10"]
["Excels","The Financial Executives Association (FEA)","Business association (other than association of financial institution)","Netherlands",null,null,null,"Typo: APPLICATION REQUIRMENTS instead of APPLICATION REQUIREMENTS","G1","Objectives","3"]
["Excels","The Financial Executives Association (FEA)","Business association (other than association of financial institution)","Netherlands",null,null,null,"Typo: and inESRS S1-S4.. -> misses space and includes two '.'","ESRS2","IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities and material information to be reported","AR 21"]
["Excels","The Financial Executives Association (FEA)","Business association (other than association of financial institution)","Netherlands",null,null,null,"Typo:  Can remove a in this sentence: a free, prior and informed consent ","E4","E4-4 - Targets related to biodiversity and ecosystems","AR 5"]